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The AAR ruled that the fresh water storage tank and effluent guard pond constructed by the applicant qualify as "plant and machinery" under the CGST Act, as they are integral to the core manufacturing process and not merely civil structures or buildings. Despite being constructed through civil works, these assets function as essential production apparatus, supporting uninterrupted operations and environmental compliance. Consequently, the restrictions under Section 17(5)(c) and (d) excluding input tax credit (ITC) on immovable property do not apply. The applicant's capitalization of these structures as plant and machinery in their books further substantiates their classification. Therefore, the applicant is entitled to avail ITC on GST paid for goods and services used in constructing these structures, provided they are employed in the course of taxable business activities.
The AAR ruled that the fresh water storage tank and effluent guard pond constructed by the applicant qualify as "plant and machinery" under the CGST Act, as they are integral to the core manufacturing process and not merely civil structures or buildings. Despite being constructed through civil works, these assets function as essential production apparatus, supporting uninterrupted operations and environmental compliance. Consequently, the restrictions under Section 17(5)(c) and (d) excluding input tax credit (ITC) on immovable property do not apply. The applicant's capitalization of these structures as plant and machinery in their books further substantiates their classification. Therefore, the applicant is entitled to avail ITC on GST paid for goods and services used in constructing these structures, provided they are employed in the course of taxable business activities.
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