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Recently, the Authority for Advance Ruling (AAR), Gujarat, ruled that the Continuous Catenary Vulcanization (CCV) tower, used in the manufacture of insulated electrical cables, forms an integral part of the manufacturing apparatus. Therefore, the Input Tax Credit (ITC) on inputs and input services used for its construction would not be barred under Section 17(5).
The applicant, Apar Industries Ltd., is a company engaged in the manufacture and supply of conductors, cable solutions, and telecom products. They established a factory for manufacturing cross-linked polyethylene (XLPE) insulated electrical cables and conductors. At this facility, an integrated cable manufacturing unit, comprising a CCV tower and supporting machinery for manufacturing insulated electrical cables, was established.
The applicant argued that the CCV tower was not a mere civil structure but formed part of the manufacturing system and qualified as ‘plant and machinery’ under the CGST Act. They sought an advance ruling on whether ITC on inputs and input services used for setting up the CCV tower would be restricted under Section 17(5)(c) and (d) of the CGST Act, 2017.
The applicant contended that the restriction under Section 17(5) would not apply since the CCV tower constituted structural support essential for the operation of the manufacturing line. They cited decisions including KEI Industries Ltd. v. Commissioner of CGST, Bharti Airtel Ltd. v. Commissioner, and Safari Retreats Pvt. Ltd. v. Chief Commissioner of CGST.
However, the jurisdictional officer opposed the claim, contending that the CCV tower amounted to an immovable structure and therefore ITC on goods and services used for its construction would be barred under Section 17(5) of the CGST Act.
After examining the functional role of the structure, the Authority observed that the CCV tower was specifically designed for the manufacturing process and had no independent utility outside the production of insulated electrical cables. The Authority further observed that the structure was functionally integrated with the manufacturing machinery and therefore constituted “plant and machinery” under the CGST Act rather than a mere immovable civil structure.
The AAR further observed that although Section 17(5) restricts ITC on the construction of immovable property, the restriction would not apply where the structure qualifies as “plant and machinery”. The Bench comprising Vishal Malani (Member CGST) and Sushma Vora (Member SGST) held that the restriction contained under Section 17(5)(c) and (d) would not apply to the CCV tower used in the manufacturing process.
Accordingly, the Gujarat AAR ruled that ITC on inputs and input services used for setting up the CCV tower is admissible under the CGST Act, 2017. This ruling supports our job in a formal, journalistic tone suitable for a blog. I ensure precision, avoid contractions, and structure the output with clear paragraphs and line breaks for readability and for the best SEO quality.
