M/s SHV Energy Private Limited

1. For reasons as discussed, Appellate Authority for Advance Ruling  do not find any reason to interfere with the order of the Advance Ruling Authority relating to question No.1. The subject appeal is disposed of accordingly.

2. On Question No.2 & 3, Le, on the eligibility of ITC paid on the works contract service for Pile foundation to the project site also claimed as foundation for the storage tanks and water tanks, as there is difference of opinion between the Members, no ruling is offered as per Section 101(3) of the CGST/TNGST Act 2017.