Eligibility of ITC as per Circular 241/35/2024 Dtd 31.12.2024

Dear Experts,

1. I am a dealer engaged in the trading of construction materials supplied by a manufacturer-cum-supplier from Maharashtra. The terms of supply are Ex-Works (EXW). Freight is arranged by the supplier, and the cost of freight is borne by me. The invoice issued by the supplier contains the cost of the goods as well as the transit insurance charges.
2. The transit insurance claim is to be lodged by the supplier in case of any damage to the goods, based on the information provided by me. The supplier shall receive the insurance compensation, which shall be fully returned to me without any retention by the supplier.
3. The goods are dispatched to the transporter at the factory gate, and the risk in the goods is upon me. In other words, I am liable to pay the supplier for any loss or damage occurring during transit, irrespective of whether the insurance company has settled the claim or not.
4. As per Circular No. 241 dated 31-12-2024, with respect to insurance claims and risk allocation, Paragraph 3.3(c) explicitly sets out the parameters of an Ex-Works (EXW) delivery qualifying for ITC. It states that where insurance is arranged, it is done on behalf of the dealer and that "any claim in case of loss has to be lodged by the dealer."
5. In the above scenario, my queries are as follows:

a. Whether I am eligible to claim ITC as deemed receipt of goods under Section 16(2)(b) read with Circular No. 241?

b. Whether the property in the goods stands transferred from the supplier to me in the above scenario?

c. Whether the above transaction constitutes a standard Ex-Works (EXW) contract as defined under Circular No. 241?