Plant classification under GST: functionality test determines ITC eligibility for buildings serving special technical requirements.
The expression plant or machinery in Section 17(5)(d) of the CGST Act must be interpreted by reference to functionality rather than by equating it with the statutory definition of "plant and machinery." A building qualifies as a plant for ITC purposes if, on the facts, it was planned and constructed to serve the assessee's special technical or operational requirements. The functionality test is fact-specific and requires case-by-case analysis of the building's role in the assessee's business.