Leasehold rights used for constructing an immovable manufacturing facility kept GST input tax credit blocked under the plant and machinery test.

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....Leasehold rights used to obtain land and set up a manufacturing facility were treated as an enabling service received for construction on the appellant's own account, so the first condition of the ITC bar under section 17(5)(d) was satisfied. Applying annexation, object, intendment and marketability tests, the Authority held that the air separation plant was an immovable manufacturing facility meant for permanent beneficial enjoyment of the leased land, not a standalone apparatus, equipment or machinery. As the facility did not fall within the statutory meaning of plant and machinery, the exclusion from the credit bar was unavailable and GST input tax credit on the leasehold-rights service remained blocked.....