Input tax credit— Section 16 of CGST Act— The present appeal has been filed  against the Advance Ruling order. 

In the instant case, the appellant manages two currency printing press units, one at Mysore and the other at Salboni, West Bengal, both of which are registered under GST; that the unit at Mysuru also has an ink manufacturing unit (Varnika) engaged in the manufacturing of ink which is used for printing the currency notes; that the supply of currency notes to RBI is exempted from GST as per Notf No 02/2017-CT (Rate) dated 28-06-2017.

The short point for determination by us is whether the lower Authority was correct in not giving a ruling on the following three questions raised by the Appellant in their application:-

Whether ITC can be claimed on common services which are utilized by Vamika IMU and the printing press at Mysuru, for both taxable as well as exempted supplies?

Whether the method followed in connection with claiming input tax credit is in accordance with law?

Which financial year's turnover is to be considered while calculating ineligible ITC under Rule 42 of CGST Rules, when the inward supply invoices were accounted in the books of account for 2019-20 but ITC claimed during April to September 2020-21?

Held that— The question “Whether ITC can be claimed on common services which arc utilized for both taxable as well as exempted supplies?” is admissible for advance ruling as it falls within the scope of Section 97(2)(d) of the CGST Act.

We uphold the findings of the Authority for Advance Ruling with respect to questions 2 and 3 of their application and hold that they are not questions on which an advance ruling can be given.

The appeal filed by the Appellant, M/s Bharatiya Reserve Bank Note Mudran Pvt Ltd, is disposed off on the above terms.