Share buybacks and GST: expenses tied to buybacks are not eligible for ITC, and common ITC must be reversed.
The authority held that shares are "securities" excluded from "goods" and "services," but section 17(3) and the Chapter V rules treat "transactions in securities" as part of the "value of exempt supply" for ITC apportionment; therefore GST paid on expenses directly related to a share buyback is not eligible as ITC under section 16(1), and common ITC attributable to both taxable operations and the buyback must be reversed using the prescribed deeming values.