In re Tvl. Armstrong Internatinal Pvt Ltd (GST AAR Tamilnadu)
The application for advance ruling filed by the applicant was received physically on 17.06.2025, after payment of the prescribed application fees under the CGST Rules, 2017 and SGST Rules, 2017. The applicant is engaged in the manufacture and sale of steam and condensate recovery systems and proposed to undertake an expansion of its manufacturing facility, alterations to the existing factory, and construction of a new corporate office. The proposed project included setting up a new factory with additional product lines, construction of a corporate office with utilities and capital goods, establishment of a customer learning and development centre with testing labs, and structural modifications to the existing factory involving installation of heavy machinery. The estimated project cost was tabulated at ₹27.91 crore across various heads such as mechanical works, electrical works, civil construction, structural works, interiors, and professional fees.
Based on these facts, the applicant sought advance rulings on the admissibility of input tax credit (ITC) on capital goods, electrical works, fire protection and alarm systems, HVAC systems, elevators, structural and pre-engineered works, civil construction forming part of the production process, and equipment installed in the customer learning centre. A personal hearing was scheduled, but the applicant requested postponement. Subsequently, by letter dated 23.10.2025, the applicant informed the authority that it wished to withdraw the advance ruling application, stating that the proposed transaction had been temporarily placed on hold due to a change in circumstances and pressing business priorities, with implementation deferred to a later date. The authority accepted the request and, without examining the merits of the issues raised, treated the application as withdrawn. Accordingly, the advance ruling application received on 17.06.2025 was disposed of as withdrawn at the request of the applicant.
