In re Alleima India Pvt. Limited (AAR Gujarat)
M/s Alleima India Pvt. Limited, registered under GST, operates industrial plants in Mehsana, Gujarat, and Hosur, Tamil Nadu. The company expanded its Mehsana plant, requiring an enhanced power load of 4500 KVA at 66KV. For this purpose, Alleima approached the Gujarat Energy Transmission Corporation (GETCO) to establish a new high-tension power connection. GETCO offered two options: (a) direct execution through its vendors, or (b) supervised installation by the applicant. Alleima chose the latter, undertaking the cable-laying work at its own cost under GETCO’s supervision, engaging M/s Rajesh Power Services Pvt. Ltd., an authorised vendor of GETCO.
The installation involved laying an underground 66 KV single-core aluminium corrugated sheathed cable line over 2.7865 km from GETCO’s substation to Alleima’s factory switchyard. The process included excavation of trenches, laying of high-voltage cables through ducts, and using double-wall corrugated or Hume pipes for safety where the cables crossed roads. All work was executed under GETCO’s supervision to ensure reliability and compliance with technical standards.
Applicant’s Request and Contentions
Alleima sought an advance ruling on whether it could avail Input Tax Credit (ITC) on the procurement of capital goods and related services, such as wires, cables, electric equipment, supervision charges, and installation services used for electricity transmission from GETCO’s substation to its factory premises, installed outside the factory limits.
The applicant contended eligibility for ITC under Sections 16 and 17 of the CGST Act, 2017, citing:
