Rajasthan GST Advance Ruling RAJ/AAR/2026-27/08: Application Withdrawn
The Authority for Advance Ruling in Rajasthan did not issue a decision because the company withdrew its request.
- Ruling
- ADVANCE RULING NO. RAJ/AAR/2026-27/08, dated 29.07.2026
- Dated
- 29 Jul 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
- The company asked about GST rates on a works contract.
- The company asked if a tax increase counts as a statutory liability.
- The company formally requested to withdraw the application during the hearing.
- The Authority accepted the withdrawal and provided no ruling on the merits.
In short
M/s MTS-EILE (JV) asked the Authority for Advance Ruling (AAR) to clarify GST rates for a construction contract, but they withdrew the request before a decision was made.
What has changed
How it worked before
Businesses often seek clarity from the AAR when they are unsure if a tax rate change qualifies as a change in statutory liability for their contracts.
What has changed
Nothing changed. Because the company withdrew its application, the Authority did not provide any legal interpretation or guidance on GST rates or contract liabilities.
Who this affects
Construction companies and contractors dealing with long-term works contracts and potential changes in GST rates.
An example
Imagine a construction firm, BuildRight India, is worried about a GST rate hike on an ongoing project. They might look at this ruling hoping for guidance on whether they can claim the extra tax from their client. However, because this ruling was withdrawn, it offers no help to BuildRight India. They would need to file their own application to get a binding answer for their specific contract.
What you should do
This order is not a legal precedent and does not apply to your business. If you have a similar question, you must file your own application for an advance ruling, as these decisions only bind the specific company that asked and their local tax office.
If you do nothing
If you assume this ruling supports your position, you risk making incorrect tax payments. A tax officer is not bound by this order and may disagree with your interpretation, leading to potential penalties and interest charges for unpaid taxes.
The terms explained
- Advance Ruling
- A written decision provided by tax authorities to a business that clarifies how GST laws apply to their specific transaction.
- Works Contract
- A contract for construction, fabrication, or improvement of immovable property where both goods and services are provided.
- Statutory Liability
- A tax or financial obligation imposed by law that a business is required to pay.
The ruling in detail
Authority for Advance Ruling
M/s MTS-EILE (JV)
ADVANCE RULING NO. RAJ/AAR/2026-27/08, dated 29.07.2026 · Rajasthan
Questions before the authority
- Whether GST @12% was correctly applicable on the date of tender invitation i.e. 24.04.2022 and on the date of bid submission i.e. 28.06.2022 for the subject contract, considering that the bid was prepared and submitted based on the GST provisions prevailing on those dates?
- Whether the increase in GST from 12% (considered in the bid on 24.04.2022 / 28.06.2022) to 18% paid on works executed and billed on or after 19.07.2022 pursuant to Notification No. 03/2022-Central Tax (Rate) dated 13.07.2022 shall be treated as additional statutory tax liability/change in tax for the said ongoing contract?
Facts
The applicant was awarded a composite works contract for the construction, operation, and maintenance of a Faecal Sludge Treatment Plant. They sought a ruling on whether the GST rate of 12% considered at the time of bidding was correct and if the subsequent increase to 18% constitutes an additional statutory tax liability. During the personal hearing, the applicant requested to withdraw the application.
Ruling
| Question | What the authority ruled |
|---|---|
| Withdrawal of application | Withdrawn The applicant requested to withdraw the application with liberty to file a fresh one. |
The Authority did not provide a ruling on the merits of the questions raised. Because the applicant formally requested to withdraw the application during the personal hearing, the request was accepted and no ruling was given.
Reasoning
The Authority noted that the applicant's authorized representatives appeared for the personal hearing and explicitly stated their intent to withdraw the application. Consequently, the Authority considered the request and granted the withdrawal. No substantive legal analysis or interpretation of the GST provisions was performed as the matter was closed upon the applicant's request.
Provisions relied on
- Section 97(2) of CGST/SGST Act, 2017
For the practitioner
This order provides no guidance on the merits of GST rate applicability or the classification of tax increases as statutory liabilities. It serves only as a procedural record of the **withdrawal of the application** by the taxpayer. Practitioners should note that this ruling does not establish any precedent for similar ongoing contract disputes.
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/6-mts_eile-withdrawl_1.pdf
Legibility of the scan, as read: high.
Prepared 10-09-2026.
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