LNG Pipeline Construction Denied Input Tax Credit Due to Infrastructure Classification Under CGST Section 17

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....The AAR ruled that the Tie-in pipeline, which transfers re-gasified LNG from FSRU to the National Grid, does not qualify as "plant and machinery" under Section 17 of the CGST Act. Despite using various technical systems and devices, the pipeline remains a structure laid outside factory premises. Consequently, the applicant is precluded from claiming Input Tax Credit (ITC) for GST paid on goods and services used in constructing the pipeline, as per Section 17(5)(c) and 17(5)(d) of the CGST Act, 2017, as amended by the Finance Act 2025.....