OnOn May 8, 2026, the Gujarat Authority for Advance Ruling (GAAR) confirmed that manufacturers can claim Input Tax Credit (ITC) on CCV Towers used in cable production. The ruling classifies these towers as “plant and machinery” under GST law, which allows ITC eligibility.
Case Background: Apar Industries Ltd.
In this case, Apar Industries Ltd. constructed a Catenary Continuous Vulcanization (CCV) Tower through an EPC contractor. The company uses this specialized structure in its insulated cable manufacturing process.
Apar Industries requested clarification on whether GST paid on construction services and materials qualified for ITC or fell under blocked credit provisions outlined in Section 17(5)(d) of the CGST Act.
Why CCV Towers Matter in Cable Manufacturing
CCV Towers play a critical role in cable manufacturing. Manufacturers rely on their vertical design to:
- Ensure uniform insulation curing
- Prevent cable sagging or deformation
- Maintain consistent product quality
The tower functions as both structural support and an operational component of the manufacturing system.
Applicant vs. Revenue Argument
Apar Industries argued that the CCV Tower serves a highly specialized and essential manufacturing function. The company applied the “functional test”, which courts often use to determine whether a structure qualifies as plant and machinery.
In contrast, the Revenue classified the tower as an immovable civil structure and attempted to block ITC under Section 17(5)(d) of the CGST Act.
GAAR’s Final Ruling
GAAR sided with Apar Industries and confirmed that the CCV Tower directly supports the manufacturing process. The Authority determined that:
- The tower exists solely to support cable production
- Its design depends entirely on technical manufacturing requirements
- It qualifies as plant and machinery, not a general civil structure
As a result, ITC applies to the construction costs of the CCV Tower.
