Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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The AAR ruled that the applicant is not eligible to avail Input Tax Credit (ITC) on tax paid for inputs and input services related to mutual fund subscription and redemption activities. The Authority rejected the applicant's contention that redemption of mutual funds differs from sale of securities, clarifying that redemption constitutes a sale transaction regardless of nomenclature, as it involves cessation of ownership by the unit holder. Consequently, the applicant must reverse ITC on common inputs and input services used for mutual fund subscription and redemption activities in accordance with Section 17(2). The applicant's argument regarding lack of statutory machinery provisions to calculate exempt supply value was also dismissed.
The AAR ruled that the applicant is not eligible to avail Input Tax Credit (ITC) on tax paid for inputs and input services related to mutual fund subscription and redemption activities. The Authority rejected the applicant's contention that redemption of mutual funds differs from sale of securities, clarifying that redemption constitutes a sale transaction regardless of nomenclature, as it involves cessation of ownership by the unit holder. Consequently, the applicant must reverse ITC on common inputs and input services used for mutual fund subscription and redemption activities in accordance with Section 17(2). The applicant's argument regarding lack of statutory machinery provisions to calculate exempt supply value was also dismissed.
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