The Applicant is constructing Industrial buildings which are to be rented out as godowns for commercial purposes. The Applicant is seeking advance ruling on the question that whether the Applicant is entitled to claim ITC on inward supply of goods or services used for construction of such godowns. The Applicant contended that Section 17(5)(d) of CGST Act is not applicable in the given case as the godowns are not to be used for furtherance of business. Rather, such godowns themselve are a source of income. Further, as per Article 14 of Constitution of India, ITC can’t be denied on ground of “equal protection of law”.