Input Tax Credit on QIP funding allowed only for borrowings repaid for business operations, not subsidiary investment

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....Input tax credit on QIP-related services was allowed only to the extent the funds were used for repayment or pre-payment of borrowings, because that use was held to be in the course or furtherance of business and incidental to business operations. The authority treated discharge of borrowings as improving liquidity, reducing interest burden, and strengthening business, thereby satisfying the nexus under Section 16(1). ITC was denied for the portion of proceeds invested in the wholly owned subsidiary, since the holding company and subsidiary are distinct legal entities and any benefit to the parent was only indirect, leaving no direct business nexus. The appeal was partly allowed.....