Case of Shibaura Machine India Private Limited, AAAR Tamil Nadu Ruling Dated 18th December 2025. The appellate authority upheld the AAR ruling that the taxes under GST paid on the electrical installation work carried out for expansion of factory for manufacturing activity is not eligible for availment of Input Tax Credit (ITC) by the applicant, as it is blocked under Sections 17(5)(c) and 17(5)(d) of the CGST Act.