ADVANCE RULINGS
1. Shibaura Machine India Pvt. Ltd. (AAR Order No.32/ARA/2025 dt.18.8.2025)(TN)
Manufacturer expanding factory sought ITC on electrical works. AAR held that contract was a works contract creating immovable property; electrical installations not plant and machinery; ITC blocked under sections 17(5)(c),(d) of CGST.
FACTS
The facts are that the applicant is engaged in the business of manufacturing of injection moulding machinery and accessories. To expand their business operation and have constructed a new factory adjacent to its exiting factory, they have incurred capital expenditure towards procurement in relation to setting up of this factory. They also entered into a separate contract with supplier for installation, testing & commissioning of Electrical Works for the new factory. The said electrical work falls under SAC 995461 – Electrical installation services including electrical wiring & fitting services, fire alarm installation services, burglar alarm system installation services, leviable to GST at the rate of 18%.
Under above background, applicant sought AR on following questions:
“1) Whether Input Tax Credit (ITC) is eli