Input tax credit on pipelines outside factory premises was denied, including related foundation and structural support.

Input tax credit was denied for goods and services used to lay a transfer pipeline outside the factory premises because the GST definition of plant and machinery expressly excludes pipelines laid outside the factory. The exclusion applied even though the pipeline was used for inward or outward supply, and reliance on other enactments or pre-GST precedents could not override the express GST wording. The foundation and structural support for the pipeline were treated as part of the same disallowed installation, so credit on those components was also not admissible.

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Issues: Whether input tax credit was admissible on goods and services used for laying the transfer pipeline and the foundation and structural support for that pipeline.

Analysis: The statutory exclusion in the definition of plant and machinery specifically denies input tax credit for pipelines laid outside the factory premises. The pipeline in question was laid from the jetty to the terminal outside the factory area, and the exclusion applies regardless of whether the pipeline is used for inward supply or outward supply. Reliance on definitions from other enactments and on precedents under the earlier excise regime was held not to override the express GST exclusion. The foundation and structural support for such pipeline were treated as part of the same disallowed pipeline installation.

Conclusion: Input tax credit on the transfer pipeline and its foundation and structural support was held to be not admissible.

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