Finance/Compliance Consultant
75642 Points
Posted on 08 November 2026
Gypsy used for safari rides at a resort:
• Sec 17(5)(a) blocks ITC on motor vehicles for transport of persons (13 or fewer seats), except when used for further supply of such vehicles, transportation of passengers, or driving training.
• If the resort uses the Gypsy for safari rides (transporting guests within the park as a service, charged to guests), it's "transportation of passengers". ITC is allowed.
• If the safari is a free amenity bundled with the room (composite supply with accommodation as principal), it's still used for providing passenger transport as part of the business. AARs are divided. Charging separately strengthens the case.