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AAAR affirmed that the appellant is not entitled to avoid reversal of input tax credit (ITC) on common inputs and input services relating to mutual fund subscription and redemption, holding that the deeming provision in section 17(3) incorporates "transactions in securities" into the value of exempt supplies for ITC reversal. The authority rejected the contention that "securities" exclusion from goods/services removes them from exempt/non-taxable supply treatment and construed the Rule reference to "sale value" consistently with "transactions in securities," encompassing redemptions. The AAAR also found no substantiation that subscription/redemption activities were in the course or furtherance of the appellant's business. The appeal is dismissed.
AAAR affirmed that the appellant is not entitled to avoid reversal of input tax credit (ITC) on common inputs and input services relating to mutual fund subscription and redemption, holding that the deeming provision in section 17(3) incorporates "transactions in securities" into the value of exempt supplies for ITC reversal. The authority rejected the contention that "securities" exclusion from goods/services removes them from exempt/non-taxable supply treatment and construed the Rule reference to "sale value" consistently with "transactions in securities," encompassing redemptions. The AAAR also found no substantiation that subscription/redemption activities were in the course or furtherance of the appellant's business. The appeal is dismissed.
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