Sikka Ports Denied Input Tax Credit for Vessel Repairs; Section 17(5)(b) CGST Act Applied to SPV Hiring.

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....The AAAR held that the respondent, M/s. Sikka Ports and Terminals Ltd., is not eligible for availing input tax credit (ITC) on input services for repairs and maintenance of Diving Support Vessels (DSVs) and Security Patrol Vessels (SPVs) as these vessels are not used for transportation of goods. Additionally, the respondent cannot claim ITC on hiring of SPVs u/s 17(5)(b) of the CGST Act, 2017, as the hiring service was not used for making an outward taxable supply of the same category of service or as an element of a taxable composite or mixed supply.....