The Court held that commissions paid to insurance distributors relate wholly to input taxed supplies and are not creditable acquisitions, even where 75% of the risk is automatically reinsured through GST-free supplies. The Court found that overhead expenses can be partly creditable where they relate indifferently to all activities of the enterprise, including GST-free reinsurance supplies, and approved a revenue-based apportionment methodology subject to adjustment for investment activities.
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