Non-business Purpose – Impact on Input Tax Credit and Consequences

  1. Preamble

    One of the main objectives for the advent of GST was to avoid the cascading effect of the various duties and taxes that were applicable on goods and / or services and allow seamless flow of input tax credit. While the eligibility to claim the input tax credit under GST is subject to certain conditions, input tax credit on certain inward supply of goods and / or services are specified as blocked and restricted. This article attempts to carve out some of the sticky issues relating to deemed reversal of input tax credit attributable for non-business purposes and the consequences arising thereon.

  2. Provisions relating to claim of input tax credit

    2.1. A registered person is entitled to claim the input tax credit of GST paid on goods and / or services which are used or intended to be used in the course or furtherance of business, in terms of Section 16(1) of the CGST Act, 2017 (hereinafter called the ‘Act’). On the contrary, Section 17(1) the Act read with Rule 42 of the CGST Rules, 2017 (hereinafter called the ‘Rule/s’ specifies that a registered person is not entitled to claim the input tax credit attributable to the goods and / or services used by the registered person for non-business / other purposes. Further, Rule 42 specifies that the common input tax credit shall be reversed at the rate of 5% as attributable to the non-business purpose denoted as D2 apart from the input tax credit on goods and / or services exclusively used for non-business / other purposes denoted as T1. Additionally, Section 17(5) specifies certain class or kinds of inward supplies on which the registered person is not entitled to claim the input tax credit despite such inward supplies being used for the purpose of business. In other words, the registered person is not entitled to claim the input tax credit relating to the inward supplies specified under Section 17(5) of the Act even though such inward supplies are used or intended to be used in the course or furtherance of business. It is important to note that the inward supplies for personal consumption even though qualifies as non-business purpose, finds an entry in this negative list.

    2.2. On perusal of the related provisions, it is apparent that the registered person is not entitled to claim the input tax credit on the goods and / or services used for non-business / other purpose which may include personal consumption. The registered person is responsible to identify the goods and / or services which are exclusively used for non-business purpose including those used for personal consumption and reverse the corresponding input tax credit. In the event, the goods and / or services are used partly for business and partly for non-business / other purposes the registered person is entitled to claim the input tax credit attributable to business activities in terms of Rule 42. In this context, it becomes relevant to understand certain phrases used in the provisions relating to claim and reversal of input tax credit to understand what the term non-business / other purpose indicates when compared with the personal consumption – which are as follows:

    2.2.1. Goods and / or services: Section 16(1) of the Act refers to goods and / or services and not inputs and / or input services. Therefore, it is relevant to note that the GST paid on any inward supply of goods and / or services in the course or furtherance of business, would qualify as input tax credit. The legislature, insofar as claiming the input tax credit is concerned is not drawing a distinction whether the inward supply would qualify as inputs or capital goods or input services. In other words, irrespective of whether the inward supply relates to inputs or capital goods, the registered person is entitled to claim the input tax credit. Similarly, in case of inward supply of services, there should not arise a question of disallowance of input tax credit unless the conditions specified thereto are not satisfied.

    2.2.2. Used or intended to be used: Section 16(1) of the Act refers to the goods and / or services ‘used’ or ‘intended to be used’ in the course or furtherance of business. With the use of words ‘intended to be used’ in Section 16(1) of the Act, it is apparent that the goods procured by the registered person or services received by a registered person which are yet to be used either for effecting the taxable outward supplies or for the purpose of business, the registered person is entitled to claim the input tax credit of GST paid thereon on the following reasoning / grounds:

    1. Firstly, Section 16(1) of the Act enables the registered person to claim the input tax credit on goods and / or services which are yet to be used. The condition that the goods and / or services should be used is not made applicable for claiming the input tax credit at this stage. Further, the law does not impose any restriction to utilise the input tax credit even if the goods and / or services are yet to be used. Therefore, a registered person is entitled to claim the input tax credit and utilise such credit upon receipt of such goods and / or services subject to conditions specified under Section 16(2) viz., receipt of goods &tax invoice, remittance of tax by the supplier, filing of return by the supplier etc., despite such goods remaining unutilised. To illustrate, the input tax credit can be claimed even though the goods are held in ‘inventory’ as raw-materials / consumables or in the course of utilisation as ‘work-in-progress’ or in the process of completing the production as ‘semi-finished goods’ or of course when held as ‘finished goods’.

    2. Secondly, upon utilisation of goods and / or services, the purpose for which such goods are used would become relevant – whether used for the purpose of business or for non-business purpose. Section 17(1) of the Act refers to the phrase ‘used’ thereby advancing the concept of end use condition viz., for non-business / other purpose. Even if such goods are used for business purpose, the conditions specified under Section 17(5) of the Act would render such input tax credit as ineligible in certain instances viz., use of goods and / or services for exempt supplies, for construction of immovable property, for disposal by way of gift or free samples etc. Accordingly, there would emerge twin conditions insofar as end use is concerned viz., for business purpose and for the purposes other than as specified under Section 17(5) of the Act.

    In this backdrop, there arises another question on the eligibility to claim the input tax credit on inward supply of goods and / or services effected by a registered person which are yet to be used by the registered person even after a reasonable period of time. In other words, where the registered person is yet to use the goods and / or services, whether the tax office may propose to deny the input tax credit on the grounds that goods and / or services are yet to be utilised. Importantly, when the services are received and consumed in the absence of taxable outward supplies effected by such registered person. In this regard, the law laid down in the following judgments would be relevant:

    1. In Dai IchiKarkaria Limited reported in 112 ELT 353, the Hon’ble Supreme Court has held that the then CENVAT Credit Rules, did not specify any condition relating to one-to-one correlation between the inputs or input services with the final products. The manufacturer is entitled to claim the CENVAT credit of duty paid on the raw materials to be used in the production of excisable goods. The CENVAT credit is subject to reversal, only if such credit is claimed illegally or irregularly. The law laid down by the Hon’ble Supreme Court although under another Statute, equally applies to the input tax credit claimed by the registered person under the GST laws. Since the claim of input tax credit in terms of Section 16 of CGST law would not render such claim as illegal or irregular till such goods and / or services are used, it can be contended that the ratio of the judgment of the Hon’ble Supreme Court would apply. Therefore, the goods and / or services which are meant to be used for the purpose of business and which are yet to be used, the registered person would be entitled to claim the input tax credit thereon and utilise the same towards the remittance of output tax.

    2. The Hon’ble Tribunal in the case of Pratap Steel Ltd., reported in 95 ELT 584 has held that one-to-one correlation between inputs and final product is not the statutory requirement. The input tax credit pertaining to the inputs can be used.

    3. The term ‘used’ was subject matter of interpretation in various judgments under the Income Tax laws. The Hon’ble Bombay High Court in the case of Viswanath Bhaskar Sathe reported in 5 ITR 621 in a matter regarding allowance of depreciation under the provisions of Income Tax law has held that the word ‘used’ in the relevant provision may be given a wider meaning and embraces passive as well as active usage. The machinery which is kept idle may well depreciate. On such basis, the Hon’ble High Court held that the assessee is entitled to claim the depreciation even if such machine is kept idle.

    4. In the case of Capital Bus Service (P.) Ltd., the Hon’ble Delhi High Court has interpreted the expression ‘used for the purpose of business’ and held that such an expression comprehends cases where the machinery was kept ready by the owner for its use in his business and the failure to use it actively in the business was not on account of its incapacity for being used or its non-availability. It is sufficient if the machinery in question was employed by the assessee for the purposes of the business and it was kept ready for actual use in the profit-making apparatus the moment a need arose.

    There are other judgments under the Income Tax laws interpreting the words ‘used’ or ‘used in the course of business’ insofar as claiming of depreciation is concerned. It is relevant to note that Section 16(1) of the Act uses the words ‘used’ and also ‘intended to be used’. Accordingly, the term ‘used’ is read as ‘intended to be used’ in the above referred judgments and therefore, the phrase ‘intended to be used’ under the GST law is inferred to be of a much wider meaning. As such, the input tax credit can be understood to be eligible despite such goods and / or services are yet to be utilised but again would be subject to twin conditions as explained supra.

    2.2.3. Business: The term ‘business’ as defined under the GST law includes any trade, commerce, manufacture, profession, vocation, adventure, wager or any other similar activity whether or not for it is for a pecuniary benefit and further includes any activity or transaction which may be connected, or incidental or ancillary to the trade, commerce, manufacture, profession, vocation, adventure, wager or any other similar activity. The definition covers in its ambit any activity whether or not such activity is carried on consistently, on regular basis, with or without a profit motive and irrespective of volume or quantum of such business. There is neither a requirement of continuity nor frequency of such activities or transactions for them to be regarded as ‘business’. The law poses no restriction that the goods and / or services must be used in a factory or premises of the service supplier, or that they must be supplied as such or as part of other goods and / or services. It would be sufficient if the goods and / or services are used in the course of business, or for furtherance of the business. The term ‘course of business’ is one phrase that can be stretched beyond the boundaries and would also include the activities which have no nexus to the business in addition to the direct nexus to the outward supply. What is usually done in the ordinary routine of a business by its management is said to be done in the “course of business”. Therefore, the meaning of the business insofar as allowing the claim of input tax credit is concerned should not be subjected to disallowance by construing the narrow meaning of the term ‘business’. In other words, the term ‘business’ as defined under the GST law is a comprehensive definition and would include any activity which is undertaken by the supplier.

    It is relevant to note that the erstwhile VAT laws defined business to include ‘any trade, commerce or manufacture or adventure in the nature of trade, commerce or manufacture’ whereas the GST laws include any ‘adventure’ to qualify as business. The judgment under the pre-GST regime where it was held that certain activities would not qualify as ‘business’ and therefore, the dealer is not liable to VAT,are no more relevant under the GST laws in ascertaining whether such activity would qualify as business for exigibility to tax. As such, the judgments in the pre-GST regime laws viz., sale of scrap1, sale of unserviceable parts and spares by road transport corporation2, sale of publications by religious trust3, sale of business as a whole4 etc., would not be of relevance under the GST regime. Therefore, the phrase ‘non-business’ should be construed ‘accordingly under the GST regime’ and the claim of input tax credit for non-business purpose should be ascertained in view of the comprehensive definition of ‘business’. Similarly, the comprehensive definition of ‘business’ should be made applicable to the activities involving outward supplies and accordingly, the liability to pay GST should be ascertained. It is pertinent to note that claim of input tax credit and liability to pay GST should not be construed as inextricably connected. In other words, it would be incorrect to state that output tax is not liable to be paid on the ground that the input tax credit relating to the inward supplies have not been claimed. As such, the word ‘business’ should be interpreted in the same manner for claiming input tax credit and for payment of output tax as well. Accordingly, the meaning of the term ‘non-business purpose’ referred under Section 17(1) read with Rule 42(1) should be construed.

    2.3. Certain issues in ascertaining ineligible input tax credit:

    2.3.1. Personal consumption: Generally, personal consumption in the context of claiming input tax credit is understood to mean consumption of goods and / or services for the personal benefit of employees, proprietor, partner, director or any other person. In other words, such consumption shall not derive any benefit to the business of the registered person. Therefore, personal consumption can be regarded as the class of goods and / or services which have no direct and proximate nexus to the business. Such class of inward supplies would constitute ‘personal consumption’.

    There can be certain inward supplies which are meant to be used for personal benefit of the persons other than for the business of registered person and certain other inward supplies, the consumption of which are partially for the registered person for business and also for non-business. Therefore, inward supplies as far as personal consumption is concerned can be categorised in the following three classes:

    1. Inward supplies used for the benefit of the business (Class T4):Certain inward supplies would be consumed by the employees or other persons of the business entity. If such consumption inherently yields direct and proximate benefit to the business of the registered person, such inward supplies would not be construed as used for personal consumption. Such inward supplies may include raw-materials, capital goods, rent / lease of office premises, flight tickets for business travel, hotel accommodation for business travel etc. Therefore, the inward supplies classifiable under this category, the registered person is entitled to claim the whole of input tax credit as T4;

    2. Inward supply not meant for the benefit of registered person for business (Class T1): This class of inward supplies are effected for the immediate and ultimate consumption for the benefit of persons which is for non-business. Neither the supplier / registered person shall not gain any benefit nor the business would derive any benefit from consumption of such inward supplies. To illustrate, entertainment expenses for the employees, theme party expenses, holiday package expenses for employees or other persons are classifiable under this category. Therefore, the registered person is not entitled to claim the input tax credit of GST paid on such inward supplies which is denoted as T1;

    3. Inward supplies which may or may not benefit the business (Class C2): This class of inward supplies may include such of those expenses where employees would consume but such consumption would partially be for the benefit of the business and partially for the benefit of the person consuming. To illustrate, mobile expenses, internet expenses, telephone expenses etc. The inward supplies classifiable under this category, the registered person is entitled to claim the input tax credit attributable to the consumption for business purpose subject to the end use condition.

    The registered person should categorise all the expenses in the above manner to ascertain the eligible and ineligible input tax credit. Such a classification would be adopted to ascertain what is the common input tax credit (C2) and how much of the input tax credit claimed by the registered person is liable to be reversed.

    2.3.2. Identification of input tax credit at invoice level: Section 17(5) of the Act has an overriding impact on Section 16 of the Act. In terms of Section 17(5)(g) of the Act the registered person is not entitled to claim the input tax credit on goods and / or services used for personal consumption. Therefore, it is apparent that inward supply of goods and / or services if meant for personal consumption, the GST paid thereon would be blocked.

    It is relevant to note that there may arise a situation, where the inward supply of goods and / or services are initially meant for business purpose and subsequently such goods and / or services are used for personal consumption. In such a scenario, in terms of Section 17(1) of the Act, such use would qualify as non-business purpose and accordingly, the registered person would be liable to reverse the input tax credit in the month in which such goods and / or services are put to use along with applicable interest. In this scenario, there may arise following situations:

    1. Where the goods and / or services are used for non-business purpose are identifiable at invoice level and the value / input tax credit can be segregated, the registered person is liable to reverse the actual amount of input tax credit (T1) identified as such. This would be precisely classifiable as T1 category of inward supplies as explained supra. To illustrate, a registered person engaged in trading of mobile phones may retain one mobile phone for personal use out of 20 units purchased. In such a case, actual amount of input tax credit claimed is ascertainable and accordingly, such registered person should reverse the actual credit.

    2. Where the goods and / or services used for personal consumption are not identifiable at invoice level viz., on expenses such as mobile charges, internet chares, etc. This would be precisely classifiable as C2 category of inward supplies as explained supra. Such registered person should apply formula specified in Rule 42 to ascertain the ineligible input tax credit only on the input tax credit claimed on the identified inward supplies (C2 Class).

    2.3.3. Ascertaining the common input tax credit: The proviso to Rule 42(1)(m) provides an option to the registered person to identify and segregate or classify the input tax credit relating to the non-business purpose at invoice level. Accordingly, the registered person may reverse the input tax credit on identified class of inward supplies. However, it should be established that the methodology and basis adopted by the registered person to identify and segregate or classify the input tax credit at invoice level is appropriate. In such a situation the registered person shall reverse the input tax credit as T1 in which case there does not arise a question of ascertaining the common input tax credit as C2.

    In the event the registered person is unable to identify and segregate the input tax credit relating to non-business purpose at invoice level, there arises a legal requirement to follow the formula specified under Rule 42. In such a scenario, only the input tax credit relating to the inward supplies used partly for non / business purpose would qualify as common input tax credit and nothing else. The registered person should at the least identify which of those expenses are put to use for non / business purposes and reverse 5% of such input tax credit (Class C2).

    To illustrate, the input tax credit on mobile expenses, telephone expenses, internet expenses etc., if not identified and segregated at the invoice level, such expenses shall alone qualify as common input tax credit (as C2 and nothing else) and is liable to be reversed at the rate of 5%. Other common expenses for taxable and exempt outward supply would not qualify as common expenses for business and non-business purpose such as rental expenses, security expenses, advertisement expenses. Such expenses are for the business purpose and therefore, would not qualify as common credit (C2) for reversal of input tax credit.

    2.3.4. Amount of input tax credit to be reversed: Rule 42(1)(j) specifies that 5% of the common input tax credit shall be reversed. There arises another question whether irrespective of the value of the input tax credit used for non-business purpose, is it mandatory for the registered person to reverse the input tax credit at the rate of 5%. The ability of the registered person or based on the facts of each case, if the common inward supplies used are unable to be identified, only in such situation input tax credit is liable to be reversed. In a situation where the inward supplies are identifiable and the value can be segregated, the registered person may not have an option to reverse the input tax credit at 5% instead, should ascertain the actual amount of input tax credit for non-business purpose in terms of Rule 42(1)(m). As such, it can be concluded that deemed reversal at 5% is applicable in a situation where the identification and segregation is not possible. As a corollary, 5% is not an option but a conclusion that invoice level identification and segregation of input tax credit is not possible.

    2.4. Consequences of reversal of input tax credit: It can be inferred that the reversal of input tax credit on the ground that the goods and / or services are used for non-business purpose would also have an adverse impact in allowing such expenses under the provisions of Income Tax laws. As a corollary, the expenditure disallowed under the provisions of Income Tax laws on the grounds that such expenditure or portion of such expenditure is not incurred in the course of business would have an adverse impact in claiming the input tax credit. In other words, if any of the expenditure or part of the expenditure is disallowed as not incurred in the course of business, it is envisaged that there arise challenges in claiming input tax credit on such expenditure. However, the provisions specified under the Income Tax laws for dis / allowance of expenditure and the definition of various terms therein vis-à-vis the definition of such terms under the GST laws would become relevant.

    2.4.1. ‘Business’ under GST law may not be the ‘business’ under Income Tax laws: In terms of Section 2(13) of the Income Tax law, the term ‘business’ is defined to include any trade, commerce or manufacture or any adventure or concern in the nature of trade, commerce or manufacture. Existence of trade, commerce or manufacture is must under the Income Tax laws even if the activity qualifies as adventure or concern. In other words, adventure or concern would not qualify as business under the Income Tax law unless such adventure or concern is in the nature of trade, commerce or manufacture. However, as explained supra, the definition of the term ‘business’ is comprehensive under the GST law and any activity carried on by a person irrespective of whether such activity is carried on consistently or on regular basis or for a profit motive or volume or quantum under the provisions of GST laws. Additionally, Income Tax laws consciously provides for separate definition for ‘profession’ to include vocation. This is how the meaning of the term ‘business’ under the Income Tax law is not as broader than the term ‘business’ under the GST laws. Whether the particular income is a business income or professional income would be relevant in assessing the tax liability under the provisions of Income Tax laws. Whereas ‘profession’ is nothing but a business under the GST laws. Therefore, there appears unambiguous difference in the definition of the term ‘business’ under both the statutes. As such, reference to the dis / allowance of an expenditure should not impact the eligibility to claim the input tax credit.

    2.4.2. Objective is different: The objective of assessment under the Income Tax laws is to assess the net profit liable to tax. Whereas, under the GST laws, the objective is to ascertain the eligibility to claim the input tax credit and payment of output tax. Further, the GST laws provides restriction in claiming input tax credit with reference to the type of recipient of goods and / or services, concessional rate of tax, nature of inward supply, usage of inward supply etc. Whereas, under the Income Tax laws, probably the emphasis is placed on the nature of expenses whether business expenditure or otherwise. Therefore, drawing reference inter-se between the Income Tax laws and GST laws would be an incorrect proposition in many circumstances.

    2.4.3. Method of assessment: The Income Tax law provides for separate provisions for assessment of tax under the provisions of Income Tax laws. With reference to the comprehensive definition of ‘business’ any activity which would qualify as supply is liable to GST. However, under the Income Tax laws, such an activity would be taxable under the heads other than ‘profits and gains of business or profession’ and the said income would qualify as consideration for supply of goods and / or services in the course of business under the GST laws. To illustrate, few:

    1. Rental income would be subjected to tax under the head ‘income from house property’ whereas the same is taxable as supply of service in the course or furtherance of business under the GST law;

    2. The input tax credit on expenditure incurred prior to setting up of the business, subject to conditions, would be eligible. The Income Tax laws allows the expenditure incurred during the previous year only. In terms of Section 3 of the Income Tax law, the expenditure incurred prior to setting up of the business will not be considered as incurred during the previous year since, the previous year is construed as beginning from the date of setting up of the business (in case of new business) and not earlier.

      Further, it is relevant to note in this context that the GST laws do not specify restriction in claiming input tax credit on the capital goods upon commencement of commercial production as specified under the erstwhile laws. Therefore, it is inferred that the GST paid on expenses incurred prior to setting up of the business or prior to commencement of the business would be eligible for availment of input tax credit.

    3. In terms of Section 35D of the Income Tax Act, the expenses incurred prior to the commencement of business qualify as preliminary expenses which will be allowed as expenses over a period of five years. However, GST law do not specify such conditions and such, the inward supplies effected prior to commencement of the business, the registered person is entitled to claim the input tax credit subject to Section 18.

    2.4.4. Restriction in claiming input tax credit vis-à-vis allowance of expenditure: Even otherwise a distinction may be drawn between Income Tax laws and GST laws in allowing the expenses or input tax credit, it shall be noted that both the statutes follow the same underlying principle for business purpose. However, the quantum of disallowance under the GST laws is either at actuals – if the inward supplies are identified and segregated which can be construed as in line with the Income Tax laws or otherwise 5% of the common credit. The fact that the expenditure which is subject to disallowance is assessed under the Income Tax laws shall be the basis for ascertaining the input tax credit in which case the registered person would not have an option for deemed reversal at 5%. Voluntary disallowance of expenditure or acceptance of disallowance of expenditure can be construed as the identification and segregation by the registered person himself. Therefore, disallowance under GST at 5% while accepting the disallowance under the Income Tax laws would be an unfavourable situation for the registered person. In cases where the registered person contests that the assessment under the Income Tax laws cannot be considered as basis for the GST laws, deemed reversal of 5% can be taken as grounds to draw distinction between the two statutes. Additionally, it can also be submitted, basis on which the disallowance of expenditure is ascertained, that invoice level identification and segregation by the registered person is mandatory to apply proviso to Rule 42(1)(m).

    2.4.5. Certain allowable expenditures under the Income Tax laws are specified as ineligible under the GST laws: The GST law and Income Tax law, insofar as allowing the input tax credit or the expenses are based on the same underlying principle viz., allowable only if incurred in the course of business. However, the GST law is inconsistent with the Income Tax law inasmuch as input tax credit is restricted on certain specified inward supplies while such expenses are allowed as business expenditure under the later enactment. To illustrate, few of the inward supplies which are allowable as business expenditure under the Income Tax laws, the Authority of Advance Ruling has denied the claim of input tax credit:

    1. The amount of GST paid on rent free hotel accommodation5provided to the General Manager of Managing Director of the Company as rent free accommodation is not eligible inward supply for claiming input tax Credit.

    2. The inward supplies relating to maintenance of township, guest house, hospital, maintenance and security etc., for the welfare of employees is not in the course or furtherance of business and accordingly, the GST paid thereon is not eligible to be claimed as input tax credit6.

    3. Input tax credit of GST paid on rent-a-cab services is not allowable as input tax credit under the GST regime.

    4. The goods disposed as samples in the course of business are allowable expenditure under the Income Tax laws. However, the registered person is not entitled to claim the input tax credit on such disposal.

  3. Conclusion: In the above backdrop, one may draw the following conclusion/s

    1. That input tax credit claimed by the registered person in terms of Section 16(1) of the Act is provisional till the time the inward supplies are used for business which fact alone will render such input tax credit as eligible in terms of Section 17(1) of the Act;

    2. The phrase ‘non-business purpose’ can only include personal consumption – probably all the inward supplies would be consumed by the employees, proprietor etc. The purpose of such consumption – whether the business is deriving the benefit would render the input tax credit as eligible;

    3. The disallowance of input tax credit for personal consumption should be consistent with the disallowance of expenditure under Income Tax laws. However, the registered person may contest otherwise based on the nature of expenditure disallowed or the input tax credit is proposed to be reversed;

    Disallowance of input tax credit under Section 17(5)(g) of the Act at a transaction level would be conclusive and therefore, there should not arise a situation to reverse the input tax credit as D2. Similarly, at a transactional level, if the input tax credit is for personal consumption is not ascertainable, the registered person should reverse the input tax credit attributable to such use as D2.

    An attempt has been made in this article to make a reader understand the issues involved under the GST laws. This article is written with a view to incite the thoughts of a reader who could have different views of interpretation. Disparity in views, would only result in better understanding of the underlying principles of law and lead to a healthy debate or discussion. The authors can be reached on [email protected] and [email protected]

(Source : Article published in Souvenir released at National Tax Conference held at Katra on 2nd & 3rd October, 2021)

 

  1. State of Tamil Nadu v. Burmah Shell Oil Co 31 STC 426 – Supreme Court

  2. State of Orissa v. Orissa Road Transport Co. Ltd., 107 STC 204 – Supreme Court

  3. CST v. Sai Publication Fund 126 STC 288 Bombay High Court

  4. Sri Ram Sahai v. CST 14 STC 275 – Allahabad High Court; DCCT, Coimbatore v. K. Behanan Thomas 39 STC 325 and Monsanto Chemicals of India (P.) Limited v. State of Tamil Nadu 51 STC 278 – Madras High Court

  5. Posco India Pune Processing Centre Private Limited – 2019 (2) TMI 63 – AAR, Maharashtra

  6. National Aluminum Company Ltd – 2018 (10) TMI 748 – AAR Odisha; 2019 (2) TMI 1527 – AAAR, Odisha

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