I’m Simran, a recent CA Finalist (awaiting results, fingers crossed!) specializing in taxation, and I’m currently grappling with a tricky GST ITC scenario from my articleship days that still puzzles me. We had a manufacturing client in Indore who incurred significant expenses on renovation of their factory’s administrative block – new cabin partitions, AC installations, false ceilings, etc. All these were essential for their business operations. The vendors charged GST correctly. My Principal’s initial stance was that ITC would be available as these aren’t ‘immovable property’ in the strict sense, especially with the fixtures being removable. However, a senior colleague pointed towards Section 17(5)(d) of the CGST Act, regarding ‘works contract services for construction of an immovable property’ and potentially also 17(5)(c) for ‘goods or services or both received by a taxable person for construction of an immovable property’. This left us in a dilemma. How do seasoned professionals practically distinguish between eligible repairs/maintenance (where ITC is typically available) and ‘construction of an immovable property’ (where ITC is blocked) for interior fit-outs and infrastructure upgrades? The line feels incredibly blurred, and I’m looking for practical guidance or any ICAI pronouncements/judicial precedents that provide clarity on such ambiguous cases, especially for non-structural interior works.