The Gujarat Authority for Advance Ruling has ruled that Apar Industries Ltd. is eligible to claim Input Tax Credit (ITC) on goods and input services used for setting up a Continuous Catenary Vulcanisation (CCV) tower at its manufacturing facility. The CCV tower is used in the manufacturing process of insulated electrical cables.
A bench including CGST Member Vishal M. Ladani and SGST Member Subham Roy passed the ruling in an application submitted by Apar Industries Ltd.
“On going through the layout of the CCV tower and the process undertaken at different levels in the CCV tower as detailed in para 15 above, we are in agreement with the applicant’s averment that the CCV tower made of specialised steel structure is essential to support and erect the CCV lines. It is more so since the applicant has stated that the specialised steel structure in the form of CCV tower serves as a critical and essential structural support system to the entire CCV machine line for the manufacture of insulated cables, while maintaining the structural integrity, stability, precision and overall efficiency of the support system for the manufacture of insulated cables,” the Authority stated.
The applicant informed the authority that it was establishing a new manufacturing unit for high-voltage XLPE-insulated electrical cables. As part of the production setup, the company planned to install a Continuous Catenary Vulcanisation (CCV) tower, considering it an essential component of the manufacturing process.
The applicant, the CCV tower, was a specialised vertical steel structure made to support machinery used in vulcanisation and continuous cable manufacturing processes. The applicant said that the tower was not just a civil structure. It was a crucial structural support system for the plant and machinery.
The applicant, before the authority, claimed that no restriction applies to the availment of ITC on construction-related goods and services. Also, it added that the CCV tower comes under the ambit of “plant and machinery” under the CGST Act.
The applicant put reliance on CBIC Circular No. 219/13/2024-GST dated June 26, 2024. As per the circular, the furnished clarification is that the availability of ITC on ducts and manholes used in optical fibre cable networks.
Further, the applicant put reliance on the Gujarat Appellate Authority for Advance Ruling’s decision in KEI Industries Ltd. involving a similar CCV tower structure.
Read Also: Gujarat GST AAR Allows ITC on Input Services for Structural Supports of Plant & Machinery
The AAR, considering the claim, said that the CCV tower maintained structural integrity, stability, precision, and operational efficiency of the manufacturing line. Hence, it plays a significant support system for the manufacture of insulated cables.
Also, the bench held that the exclusion concerning “land, building, or civil structures” under the definition of plant and machinery shall not be applicable. It stated that the CCV tower was integrally connected with the manufacturing process.
Based on the CBIC circular regarding optical fibre cable ducts and manholes, the Authority determined that if input tax credit (ITC) is permitted for support infrastructure essential for transmission systems, then the same treatment should apply to the CCV tower that supports insulated cable manufacturing lines.
Consequently, the Gujarat AAR ruled that Apar Industries Ltd. is entitled to claim ITC on the inputs and input services used for the construction and installation of the CCV tower at its manufacturing facility.
| Case Title | M/s. Apar Industries Ltd. |
| GSTIN | 24AAACG1840M3ZP |
| Date | 08.04.2026 |
| For The Applicant | Shri Amit Laddha and Shri I.C.Thakur |
| Gujarat GST AAR | Read Order |
