2026-VIL-153-AAR

SGST Advance Ruling Authority

GST – Tamil Nadu AAR - Eligibility to input tax credit on land survey charges incurred for the purchase of land used to meet afforestation obligations and directly linked to operation of golf course business - Applicant, a heritage golf club using forest land for golfing facilities, engaged a registered land surveyor to identify forest land utilized for golfing and evaluate suitable alternate land for afforestation purposes as part of compliance with regulatory obligations - The surveyor issued GST invoices for survey charges which were duly paid - Whether input tax credit is admissible on GST paid for land survey charges for purchase of land used to meet afforestation obligations, directly linked to operation of golf course business – HELD - Input tax credit is not admissible as the land surveyed for alternate land to be handed over to Forest Department does not represent goods or services used in furtherance of business since it does not generate independent economic benefits and does not remain in possession of the Applicant - Surveying charges incurred for golf course construction constitute services received for construction of immovable property on own account, and input tax credit is blocked under Section 17(5)(d) CGST Act, 2017. Surveying charges used for alternate land which is surrendered to Forest Department and written off in books are blocked under Section 17(5)(h) CGST Act, 2017 as goods written off or disposed – Further, land is explicitly excluded from plant and machinery, hence services related to land are not eligible for input tax credit under Schedule III CGST Act, 2017 – Input tax credit is not admissible on GST paid for land survey charges – Ordered accordingly

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