Maharashtra GST Advance Ruling Order GST-ARA-08/2024-25/B45: Application Withdrawn
The Authority for Advance Ruling allowed the applicant to withdraw their request, meaning no decision was made on their GST status.
- Ruling
- NO.GST-ARA-08/2024-25/B- 45, Mumbai, dt. 13/03/2026
- Dated
- 13 Mar 2026
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- Ani Technologies asked about their status as an e-commerce operator.
- The company questioned their GST liability for passenger transport services.
- The applicant voluntarily withdrew their request before a ruling was issued.
- The Authority did not examine the merits of the proposed business models.
In short
Ani Technologies, the company behind Ola, asked the Maharashtra Authority for Advance Ruling (AAR) to clarify how GST applies to their passenger transport business models. Before the authority could decide, the company asked to withdraw their application. Because the request was withdrawn, the authority closed the case without providing any guidance or legal interpretation.
What has changed
How it worked before
Businesses often seek advance rulings to get certainty on how tax laws apply to new or complex business models.
What has changed
Nothing changed. Because the application was withdrawn, the authority did not issue a decision. This order provides no guidance on whether a platform is an e-commerce operator or liable for GST on passenger transport services.
Who this affects
This order is relevant to any business operating an online platform for passenger transport services that is considering seeking a GST advance ruling.
What you should do
Do not rely on this order for tax planning. An advance ruling is only binding on the business that requested it and its specific tax officer; since this case was withdrawn, it holds no legal weight for anyone else.
If you do nothing
If you assume this order sets a precedent, you risk miscalculating your tax liability. Tax officers are not bound by withdrawn applications and may take a different view of your business model. Relying on non-existent guidance can lead to penalties and interest charges during a tax audit.
The terms explained
- Advance Ruling
- A formal decision by tax authorities on how GST laws apply to a specific business transaction.
- E-commerce operator
- A person who owns, operates, or manages a digital platform for electronic commerce.
- Section 9(5) of the CGST Act
- A specific rule that makes certain e-commerce platforms responsible for paying GST on services provided through them.
The ruling in detail
Authority for Advance Ruling
M/s. ANI TECHNOLOGIES PVT. LTD.
NO.GST-ARA-08/2024-25/B- 45, Mumbai, dt. 13/03/2026 · Maharashtra
Questions before the authority
- Q 1: In light of the aforesaid proposed model-I, whether the Applicant would qualify as an Ecommerce operator under Section 2 (45) of the CGST Act?
- Q 2: In light of the aforesaid proposed model-I, whether the Applicant would be liable to pay GST on the proposed model of supply of passenger transportation services by the driver partners to the customers in terms of Section 9 (5) of the CGST Act read with Notification No. 17/2017-Central Tax (Rate) dated 28.06.2017?
- Q 3: In light of the aforesaid proposed model-I, whether the Applicant would be treated as 'supplier' in respect of the passenger transport services provided by the driver partners to the end customer?
- Q 4: In light of the aforesaid proposed model- II, whether the Applicant would qualify as an E-Commerce operator under Section 2 (45) of the CGST Act?
- Q 5: In light of the aforesaid proposed model-II, whether the Applicant would be liable to pay GST on the proposed model of supply of passenger transportation services by the driver partners to the customers in terms of Section 9 (5) of the CGST Act read with Notification No. 17/2017-Central Tax (Rate) dated 28.06.2017?
- Q 6: In light of the aforesaid proposed model-II, whether the Applicant would be treated as 'supplier' in respect of the passenger transport services provided by the driver partners to the end customer?
Facts
The applicant, M/s. ANI TECHNOLOGIES PVT. LTD., operates an electronic commerce platform under the brand name OLA. They sought an advance ruling regarding their tax liability and status as an e-commerce operator under two different proposed business models for passenger transportation services.
Ruling
The Authority for Advance Ruling did not provide a ruling on the merits of the questions presented. The applicant submitted a request to voluntarily and unconditionally withdraw their application, which was allowed by the Authority.
Reasoning
The applicant submitted a letter dated 10.03.2026 expressing their desire to withdraw the application. Consequently, the Authority allowed the request for withdrawal without examining the merits or detailed facts of the case under the provisions of the CGST Act and the Maharashtra Goods and Services Tax Act, 2017.
Provisions relied on
- Section 97 of the CGST Act
- Section 98 of the CGST Act
- Section 2 (45) of the CGST Act
- Section 9 (5) of the CGST Act
- Notification No. 17/2017-Central Tax (Rate) dated 28.06.2017
For the practitioner
This order provides **no substantive guidance** on the taxability or classification of the applicant's business models. It serves only as a procedural record of the **voluntary withdrawal** of the application by the taxpayer. Practitioners should note that this document does not constitute a precedent for the issues raised.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/2-withdrawn_order_in_case_of_ani_technologies_pvt._ltd.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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