GST Input Tax Credit on Structural Supports and Refund Timelines
The Rajasthan Authority for Advance Ruling confirmed that structural supports for machinery qualify for input tax credit and clarified refund interest timelines.
- Ruling
- RAJ/AAR/2023-24/05 dated 30.06.2023
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- Structural supports for plant and machinery are eligible for input tax credit.
- Interest on delayed GST refunds applies if not credited within 60 days.
- The authority declined to rule on common head office registration procedures.
In short
Uvee Glass Private Limited asked the Rajasthan Authority for Advance Ruling (AAR) about claiming input tax credit on structural supports for machinery, the rules for common head office registrations, and how to calculate the 60-day window for interest on delayed GST refunds.
What has changed
How it worked before
Businesses were often uncertain if structural supports fixed to the earth qualified as plant and machinery for tax credit purposes, and there was ambiguity regarding the exact end-date for the 60-day refund interest calculation.
What has changed
The authority clarified that structural supports are part of plant and machinery, making them eligible for input tax credit. It also confirmed that the 60-day clock for interest on refunds stops only when the money hits the taxpayer's bank account.
Who this affects
Manufacturers and businesses with large machinery installations or those frequently claiming GST refunds.
An example
A steel manufacturer installs heavy metal frames to support a new furnace. They wonder if they can claim the GST paid on these frames as input tax credit. Based on this ruling, they can likely claim the credit because the frames act as structural support for the machinery.
What you should do
Use this ruling as a reference for your tax position, but remember that an advance ruling only legally binds the business that asked and its specific tax officer. Consult your tax advisor to see if these findings apply to your specific factory setup or refund claim.
If you do nothing
If you assume this ruling automatically applies to your business, you risk claiming credits that your local tax officer may later disallow. This could lead to tax demands, interest charges, and penalties for incorrect filings. Always verify your specific situation with a professional rather than relying on another company's ruling.
The terms explained
- Input Tax Credit
- The tax a business pays on its purchases that it can use to reduce the tax it owes on its own sales.
- Advance Ruling
- A written decision from tax authorities on how GST laws apply to a specific business transaction.
- Structural Support
- The foundation or framework fixed to the ground that holds machinery in place.
The ruling in detail
Authority for Advance Ruling
M/S Uvee Glass Private Limited
RAJ/AAR/2023-24/05 dated 30.06.2023 · Rajasthan
Questions before the authority
- Whether, ITC is eligible on the GST paid on the inward supply of structural support of the plant and machinery that is used for making outward supply of the goods/services?
- Whether, a common head office can be used for more than one taxpayer under GST having separate factory addresses or each applicant is required to be registered with separate head office?
- Whether, as per Notification No.13/2017-Central Tax, dated June 28, 2017; time period of 60 days provided under section 56 of the CGST Act, 2017 is for the period from the date of filing application for refund to the date of credit of the refund amount in taxpayer's bank account?
Facts
The applicant is engaged in the manufacturing of various types of glass products. They sought an advance ruling regarding the eligibility of Input Tax Credit (ITC) on structural supports for plant and machinery, the permissibility of a common head office for multiple GST registrations, and the interpretation of the time period for interest on delayed refunds under Section 56.
Ruling
| Question | What the authority ruled |
|---|---|
| ITC on structural support for plant and machinery | Admissible Limited to fixing of plant and machinery to earth by foundation or structural support used for making outward supply |
| Common head office for multiple registrations | Not answered Deemed to be a procedural matter outside the scope of the Authority for Advance Ruling |
| Time period for interest on delayed refunds | From date of filing application to date of credit in bank account Based on Section 56 of the CGST Act, 2017 |
The Authority ruled that ITC is admissible on structural supports for plant and machinery to the extent they are used for making outward supplies. It declined to answer the question regarding common head office registration, stating it relates to procedural matters outside the scope of an advance ruling. Regarding the refund timeline, it confirmed the 60-day period is calculated from the date of filing the application until the credit of the refund amount in the taxpayer's bank account.
Reasoning
The Authority relied on Section 16 and 17 of the CGST Act, noting that ITC is available for plant and machinery, which includes foundation or structural support fixed to earth. Regarding the refund timeline, the Authority referenced Section 56 of the CGST Act and Circular No. 125/44/2019-GST, which clarifies that interest is payable if the refund is not credited to the bank account within 60 days of the application date. The Authority refused to rule on the head office registration issue, citing that it is a procedural question not covered under Section 97(2).
Provisions relied on
- Section 16 of the CGST Act, 2017
- Section 17 of the CGST Act, 2017
- Section 56 of the CGST Act, 2017
- Section 97(2) of the CGST Act, 2017
- Notification No. 13/2017-Central Tax
- Circular No. 125/44/2019-GST
For the practitioner
This ruling confirms that **structural supports for plant and machinery** are eligible for ITC, provided they meet the definition of being fixed to earth. It also provides clarity that the **60-day refund timeline** for interest purposes ends only when the amount is credited to the taxpayer's bank account. Practitioners should note that the Authority will **refuse to rule on procedural registration queries** that do not fall strictly under the clauses of Section 97(2).
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/raj_aar_06-2023_of_uvee_glasss_pvt_ltd.pdf
Legibility of the scan, as read: high.
Prepared 17-10-2026.
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