GST Advance Ruling 62/ARA/2025: Application Withdrawn
The Tamil Nadu Authority for Advance Ruling closed the case regarding hostel tax exemptions because the applicant withdrew their request.
- Ruling
- Advance Ruling No. 62/ARA/2025, dated 17.12.2025
- Dated
- 17 Dec 2025
- 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
- The applicant asked about GST exemptions for hostel and residential accommodation services.
- The applicant formally requested to withdraw the application before a decision was made.
- The Authority closed the case without providing any legal interpretation or ruling.
In short
The business owner asked the Authority for Advance Ruling (AAR) whether renting a property for hostel use qualifies for Goods and Services Tax (GST) exemptions. Before the Authority could decide, the owner changed their business plans and withdrew the request. Because the application was withdrawn, the Authority did not issue any guidance on how hostels should be taxed.
What has changed
How it worked before
Businesses were looking for clarity on whether hostel services qualify as exempt residential dwellings under various GST notifications.
What has changed
Nothing changed. Because the application was withdrawn, the Authority did not rule on the merits of the case, meaning there is no new precedent or guidance for other businesses to follow.
Who this affects
Property owners and hostel operators who are uncertain about their GST registration and tax exemption status.
An example
Imagine a property owner in Chennai who wants to know if their hostel business is exempt from GST. They might look at this ruling hoping for an answer. However, because the applicant withdrew their request, the ruling contains no information on the taxability of hostels. The owner must consult their own tax advisor to understand their specific obligations.
What you should do
Do not use this ruling to support any tax position. An advance ruling only applies to the specific business that requested it, and since this case was withdrawn, it provides no legal guidance for anyone else.
If you do nothing
If you assume this document provides a tax exemption for your hostel, you risk underpaying your GST. Tax officers are not bound by withdrawn applications and may issue notices for unpaid taxes, interest, and penalties. Always seek professional advice based on current law rather than relying on incomplete or withdrawn rulings.
The terms explained
- Advance Ruling
- A formal decision provided by tax authorities to a business regarding how GST applies to their specific transactions.
- Exemption
- A situation where a business is not required to collect or pay GST on certain goods or services.
- Composite Supply
- A package of two or more goods or services provided together, where one is the main service and the others are naturally bundled with it.
The ruling in detail
Authority for Advance Ruling
M/s. Gopi Damodaran
Advance Ruling No. 62/ARA/2025, dated 17.12.2025 · Tamil Nadu
Questions before the authority
- Whether the hostel and residential accommodation extended to the students and working persons by the Applicant's prospective tenant can be considered as Residential Dwelling and is eligible for exemption under Entry 12 of Exemption Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and under the identical Notification under the TNGST Act, 2017 and also under Entry 13 of Exemption Notification No.9/2017-Integrated Tax-Rate dated 28.06.2017 for the period of 01.07.2017 to 11.07.2024?
- Whether the hostel facility extended to students by the Applicant's tenant falls under Entry 12A inserted vide Notification No. 4/2024-Central Tax (Rate) dated 12.07.2024 with effect from 12.07.2024 as the conditions laid down in the Entry has been fulfilled?
- Whether the Applicant's Prospective tenant running a residential hostel be eligible for exemption under Sl. No. 12A inserted vide Notification No. 4/2024-Central Tax (Rate) dated 12.07.2024 with effect from 12.07.2024 would at all be required to take registration under the GST Enactments by virtue of the Exemption Notifications as afore mentioned and also under the provisions of Section 23 of the CGST/TNGST Act, 2017?
- Whether, in the event of the hostel accommodation being an exempt activity, whether the incidental activity of supply of in-house food to the inmates of the hostel would also be exempt being in the nature of a composite exempt supply?
- Whether the judgement of the Division Bench of the Hon'ble Karnataka High Court in the case of Taghar Vasudeva Ambrish Vs. Appellate Authority for Advanced Ruling, Karnataka reported in Manu/KA/0327/2022, is applicable to the facts of the applicant?
- Whether the judgement of the Hon'ble Madras High Court in the case of Thai Mookambika Hostel v. The Union of India reported in [2024] 160 taxmann.com 667 (Madras), is applicable to the facts of the applicant?
Facts
The applicant is a proprietary concern that owns a residential property in Coimbatore. They intended to lease this property to a tenant who would operate it as a hostel for students and working persons. The applicant sought an advance ruling on the taxability and registration requirements for this proposed hostel activity.
Ruling
The Authority did not rule on the merits of the questions presented. The applicant submitted a letter dated 14.11.2025 requesting to withdraw the application because they decided to rent the building to a tenant not engaged in the business of providing hostel services. Consequently, the application was disposed of as withdrawn.
Reasoning
The Authority noted that the applicant formally requested to withdraw their application for an advance ruling. Under the relevant procedures, the Authority accepted this request. Therefore, the application was disposed of without addressing the merits of the legal questions or the applicability of the cited notifications and case laws.
Provisions relied on
- Section 98(4) of the CGST Act, 2017
- Section 98(4) of the TNGST Act, 2017
For the practitioner
This ruling provides no guidance on the taxability of hostel services or the applicability of recent notifications. It serves only as a procedural record of the **withdrawal of the application** by the applicant. Practitioners should not rely on this document for any substantive legal interpretation.
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/4-gopi_damodaran_aar_order-1.pdf
Legibility of the scan, as read: high.
Prepared 13-10-2026.
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