Transtonnelstroy - Section 17(5)
Facts
ITC denied under Section 17(5) on goods used for construction of immovable property.
Issue
Whether items used as plant for taxable output (plant being "movable" in nature) are blocked?
Held
Plant used for taxable output is not "immovable property" for 17(5)(d); ITC allowable.
Ratio
Plant test predates Safari Retreats - confirmed functional approach to 17(5)(d).
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