GST Advance Ruling Application Rejected for Procedural Errors
The Authority for Advance Ruling rejected an application because the business failed to pay full fees and submit required manual copies.
- Ruling
- Advance Ruling No.23/ARA/2026, dated 06.03.2026
- Dated
- 06 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
- The business failed to file the mandatory manual application in quadruplicate.
- Only the state tax portion of the application fee was paid.
- The Authority rejected the application without reviewing the tax merits.
In short
Vrudhii Enterprises asked for a Goods and Services Tax (GST) advance ruling but did not follow the required filing steps. Because they missed these procedural rules, the tax authority refused to hear their case entirely.
What has changed
How it worked before
Businesses often assume that filing an online request is sufficient for an advance ruling, overlooking specific manual filing requirements.
What has changed
The Authority confirmed that both the central and state portions of the application fee must be paid, and manual copies must be submitted. Failing these steps leads to an automatic rejection of the request.
Who this affects
Any business owner planning to file an application for a GST advance ruling.
An example
Imagine a business owner wants to know if their product is exempt from GST. They file the request online but forget to mail the four required paper copies to the office. The Authority will reject this application immediately, just as they did in this case, without ever answering the question about the product's tax status.
What you should do
Ensure your application includes both the central and state fee payments and all required manual copies. Remember that this ruling only applies to the specific business that asked; it is not a general law for everyone else.
If you do nothing
If you ignore these procedural rules, your application will be rejected without the tax authority ever looking at your actual tax question. You will lose the time spent preparing the request and may have to restart the entire process from the beginning.
The terms explained
- Advance Ruling
- A formal decision from tax authorities that clarifies how GST laws apply to a specific business transaction.
- Procedural non-compliance
- Failing to follow the specific administrative steps or rules required to file a document or request.
- Quadruplicate
- Providing four identical copies of a document.
The ruling in detail
Authority for Advance Ruling
M/s. Vrudhii Enterprises
Advance Ruling No.23/ARA/2026, dated 06.03.2026 · Tamil Nadu
Facts
The applicant filed an online application for an advance ruling under Section 97 of the CGST Act, 2017. However, the applicant failed to file the required manual application in quadruplicate as mandated by Rule 107A of the CGST Rules, 2017. Additionally, the applicant failed to pay the full prescribed application fee, having only paid the SGST portion.
Ruling
The Authority for Advance Ruling rejected the application due to procedural non-compliance. Specifically, the applicant failed to file the manual application and did not pay the full application fee as required by law. Consequently, the ruling was not issued on the merits of the case.
Reasoning
The Authority noted that the applicant did not comply with Rule 107A of the CGST Rules, 2017, which requires the filing of a manual application in quadruplicate. Furthermore, the applicant failed to pay the required fee of Rs.5,000/- under the CGST Act, 2017, in addition to the SGST fee already paid. Under Section 98(2) of the CGST Act, 2017, the Authority determined that the application was liable for **rejection due to procedural defaults** and non-payment of the prescribed fees.
Provisions relied on
- Section 97(1) of the CGST Act, 2017
- Section 98(2) of the CGST Act, 2017
- Rule 107A of the CGST Rules, 2017
For the practitioner
This order serves as a reminder that procedural requirements, such as filing manual copies and paying the full prescribed fees under both CGST and SGST acts, are **mandatory for the admission of an application**. It does not provide any substantive guidance on taxability or classification. Practitioners should ensure all procedural filings are complete to avoid summary rejection of their advance ruling applications.
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/8-vrudhii_aar_order.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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