Blocked input tax credit on ambulance purchase under GST as pre-amendment law excluded motor vehicles from credit.

Input tax credit on an ambulance purchased for employees' benefit under the Factories Act was not admissible because entitlement had to be examined under section 17(5) of the GST Act as it stood when the vehicle was bought in November 2018. The later amendment effective from 01/02/2019 could not apply retrospectively. On the relevant date, motor vehicles and other conveyances were covered by the blocked-credit rule, and the employer-mandated supply exception was limited to rent-a-cab, life insurance and health insurance, not ambulances. The credit was therefore denied.

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Issues: Whether input tax credit was admissible on an ambulance purchased for employees' benefit under the requirement of the Factories Act, 1948.

Analysis: The ambulance was purchased in November 2018, so the entitlement to input tax credit had to be tested under the version of section 17(5) of the GST Act then in force. The amendment brought into effect from 01/02/2019 could not govern a prior transaction. On that date, motor vehicles and other conveyances were covered by the blocked-credit provision in section 17(5)(a). The exception for employer-mandated supplies in section 17(5)(b)(iii)(A) was confined to rent-a-cab, life insurance and health insurance and did not extend to ambulances.

Conclusion: Input tax credit on the ambulance was not admissible.

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