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    <title>2025 (10) TMI 241 - APPELLATE AUTHORITY FOR ADVANCE RULING, GUJARAT</title>
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    <description>Expenditure incurred for share buyback was held not eligible for input tax credit under GST because shares are securities, securities transactions are neither goods nor services, and section 17 treats transactions in securities as part of exempt supply. The authority therefore rejected the argument that a general business nexus under section 16 overrides the statutory restriction. It also held that input tax credit attributable to common inputs and input services used for buyback-related expenditure must be apportioned and reversed under the GST mechanism, since the deeming inclusion of securities transactions in exempt supply applies to those common credits. The denial of credit and reversal requirement were both upheld.</description>
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      <title>2025 (10) TMI 241 - APPELLATE AUTHORITY FOR ADVANCE RULING, GUJARAT</title>
      <link>https://www.taxtmi.com/caselaws?id=779445</link>
      <description>Expenditure incurred for share buyback was held not eligible for input tax credit under GST because shares are securities, securities transactions are neither goods nor services, and section 17 treats transactions in securities as part of exempt supply. The authority therefore rejected the argument that a general business nexus under section 16 overrides the statutory restriction. It also held that input tax credit attributable to common inputs and input services used for buyback-related expenditure must be apportioned and reversed under the GST mechanism, since the deeming inclusion of securities transactions in exempt supply applies to those common credits. The denial of credit and reversal requirement were both upheld.</description>
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