Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Input tax credit was held admissible on input services used to construct foundation and structural supports for solvent recovery and wastewater treatment plants within a factory, because the services had a direct nexus with manufacturing activity and were used in the course or furtherance of business. The Authority held that steel and RCC works supporting the equipment formed part of "plant and machinery" under the statutory explanation, since the structures were fixed to earth to hold apparatus used for outward supply. As the exclusion for immovable property does not extend to such foundation and support forming part of plant and machinery, the restriction in section 17(5)(c) did not apply.
Input tax credit was held admissible on input services used to construct foundation and structural supports for solvent recovery and wastewater treatment plants within a factory, because the services had a direct nexus with manufacturing activity and were used in the course or furtherance of business. The Authority held that steel and RCC works supporting the equipment formed part of "plant and machinery" under the statutory explanation, since the structures were fixed to earth to hold apparatus used for outward supply. As the exclusion for immovable property does not extend to such foundation and support forming part of plant and machinery, the restriction in section 17(5)(c) did not apply.
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