Maharashtra GST Advance Ruling on SPV Refueller Withdrawn
The Authority for Advance Ruling closed the case regarding SPV Refueller tax rates because the company withdrew its application.
- Ruling
- NO.GST-ARA-40/2022-23/B- 43, Mumbai, dt. 09/03/2026
- Dated
- 09 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
- Repos IOT India asked for a GST classification on fuel delivery vehicles.
- The company voluntarily withdrew its request before a decision was made.
- The authority closed the file without ruling on the tax rate.
In short
The company asked the Maharashtra Authority for Advance Ruling to clarify the correct HSN code and GST rate for their fuel delivery vehicles. Before the authority could issue a decision, the company chose to withdraw its request entirely. Because the application was pulled, the authority did not provide any guidance on how these vehicles should be taxed.
What has changed
How it worked before
Businesses often seek advance rulings to get certainty on how their products are classified for GST purposes.
What has changed
Nothing changed. Since the application was withdrawn, there is no new guidance or legal precedent regarding the tax treatment of these vehicles.
Who this affects
Manufacturers or sellers of special purpose vehicles who are unsure about their GST classification.
What you should do
Do not use this order as a guide for your own tax filings. An advance ruling only applies to the business that requested it, and since this one was withdrawn, it provides no information at all.
If you do nothing
If you assume this order sets a tax rate for your business, you risk applying the wrong GST percentage to your sales. Tax officers are not bound by withdrawn applications and may issue penalties if your classification is found to be incorrect during an audit.
The terms explained
- Advance Ruling
- A formal decision from tax authorities that clarifies how GST applies to a specific business transaction.
- HSN Code
- A system of numbers used to classify goods so that the correct GST rate can be applied.
- Special Purpose Vehicle (SPV)
- A vehicle designed for a specific task, such as the mobile delivery of fuel, rather than general transport.
The ruling in detail
Authority for Advance Ruling
M/s. Repos IOT India Private Limited
NO.GST-ARA-40/2022-23/B- 43, Mumbai, dt. 09/03/2026 · Maharashtra
Questions before the authority
- What is the HSN Code & GST Rate on sale of SPV Refueller?
Facts
The applicant is engaged in the manufacture of Special Purpose Vehicles designed for the door-to-door delivery of fuel, specifically High Speed Diesel. They filed an application seeking an advance ruling regarding the appropriate HSN classification and GST rate applicable to the sale of these SPV Refuellers.
Ruling
The authority did not provide a ruling on the merits of the classification or tax rate. The applicant voluntarily and unconditionally withdrew their application via email dated 02.03.2026. Consequently, the authority allowed the withdrawal and disposed of the application without addressing the substantive questions.
Reasoning
The applicant requested to withdraw their application voluntarily and unconditionally. Under the provisions of the CGST Act and MGST Act, the authority permitted this withdrawal. As a result, the authority did not proceed to examine the merits or detailed facts of the case or provide a ruling on the HSN code and GST rate.
Provisions relied on
- Section 97 of the Central Goods and Services Tax Act, 2017
- Section 98 of the Central Goods and Services Tax Act, 2017
- Section 97 of the Maharashtra Goods and Services Tax Act, 2017
- Section 98 of the Maharashtra Goods and Services Tax Act, 2017
For the practitioner
This order is **procedural only** and does not provide any guidance on the taxability or classification of SPV Refuellers. It serves as a record that the applicant chose to **withdraw their request** before a ruling was issued. Practitioners should note that this document has no precedential value regarding the substantive tax issues.
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/1-withdrawn_order_in_case_of_repos_iot_india_pvt_ltd.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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