GST Advance Ruling: Can You Ask About Your Supplier's Tax?
The Authority for Advance Ruling (AAR) will not answer questions about tax liability for services you receive as a customer.
- Ruling
- Advance Ruling No. 13/ARA/2026, dated 27.02.2026
- Dated
- 27 Feb 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
- Umapathy Poultry Farms asked about tax on transport and land leases.
- The applicant was the recipient of services, not the supplier.
- The AAR rejected the application because it only rules on your own supplies.
- The applicant withdrew the request after the AAR noted the procedural error.
In short
A business asked the Authority for Advance Ruling (AAR) if the services they bought, like transport and land leases, were exempt from Goods and Services Tax (GST). The AAR clarified that they only provide rulings on the supply of goods or services that you yourself provide, not those you purchase from others.
What has changed
How it worked before
Businesses often assumed they could use the advance ruling process to clarify the tax status of services they were paying for to ensure they were paying the correct amount.
What has changed
The AAR confirmed that under Section 95 of the Central Goods and Services Tax (CGST) Act, you cannot use this process to ask about the tax obligations of your suppliers. This means you cannot get a binding answer from the AAR regarding whether a service you receive should be taxed or is exempt.
Who this affects
Any business owner who wants to confirm if the services they are buying from vendors are subject to GST or Reverse Charge Mechanism (RCM).
An example
A bakery owner hires a logistics company to deliver cakes and wonders if they should pay GST on the delivery fee. If the bakery asks the AAR for a ruling on this, the AAR will refuse to answer because the bakery is the recipient of the service, not the provider. The bakery must instead rely on their own tax professional's interpretation of the law.
What you should do
If you are unsure about the tax status of a service you are buying, consult your tax advisor rather than filing an advance ruling. Remember that an advance ruling is only binding on the specific business that asked the question and its own tax office; it does not set a general law for all businesses.
If you do nothing
If you assume a ruling applies to your business when it does not, you risk paying the wrong amount of tax. If a tax officer disagrees with your interpretation, you may face penalties, interest charges, and the cost of defending your position in a formal audit.
The terms explained
- Advance Ruling
- A formal decision by tax authorities on how GST applies to a specific business activity.
- Reverse Charge Mechanism (RCM)
- A system where the person receiving the service pays the tax directly to the government instead of the person providing the service.
- Recipient
- The person or business that buys or receives goods or services from a supplier.
The ruling in detail
Authority for Advance Ruling
M/s. UMAPATHY POULTRY FARMS
Advance Ruling No. 13/ARA/2026, dated 27.02.2026 · Tamil Nadu
Questions before the authority
- Is the transportation of eggs through GTA services exempt, and do the RCM provisions apply in this case?
- Is the transport of eggs via railway services exempt?
- Is the lease of agricultural land for grazing hens exempt, and do the RCM provisions apply?
- Is the use of land along with a poultry shed for sheltering birds exempt, and are RCM provisions applicable?
Facts
The applicant is engaged in poultry farming, producing and packing eggs for sale without further processing. They utilize both owned and leased land for their operations and sought clarification on the taxability and RCM applicability for various transportation and land lease services they receive. The applicant initially sought an advance ruling on these issues.
Ruling
The Authority did not rule on the merits of the questions. Upon being notified that the applicant was a recipient of services rather than a supplier, the applicant requested to withdraw the application. The Authority allowed the application to be treated as withdrawn.
Reasoning
The Authority noted that under Section 95 of the CGST Act, 2017, an advance ruling is provided on questions relating to the supply of goods or services undertaken or proposed to be undertaken by the applicant. Since the applicant was the recipient of the services in question, the Authority determined that the liability to pay tax rests with the suppliers, not the applicant. Consequently, the application was deemed not liable for admission. The applicant subsequently requested to withdraw the application, which was granted.
Provisions relied on
- Section 95 of the CGST Act, 2017
- Section 97 of the CGST Act, 2017
- Section 98(4) of the CGST Act, 2017
- Section 100 of the CGST Act, 2017
- Section 103 of the CGST Act, 2017
- Section 104 of the CGST Act, 2017
For the practitioner
This ruling serves as a procedural reminder that an applicant cannot seek an advance ruling on the tax liability of their suppliers. It confirms that the **Authority for Advance Ruling** will not entertain applications where the applicant is merely a recipient of services and not the supplier. Practitioners should ensure that the applicant is the party responsible for the supply in question before filing.
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/3-umapathy_poultry_aar_order_1.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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