GST Advance Ruling GOA/GAAR/5/2018-19: Procedural Advice Not Available
The Authority for Advance Ruling rejected a request for procedural guidance on correcting past GST invoices and exchange rate calculations.
- Ruling
- Advance Ruling No. GOA/GAAR/5 of 2018-19 dated 22/01/2019
- 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 how to correct past tax distribution errors.
- The company asked for guidance on foreign exchange rate billing.
- The Authority rejected the application as it was purely procedural.
- Advance rulings cannot be used for general administrative advice.
In short
Odyssy Tour & Travels Pvt. Ltd. asked the Authority for Advance Ruling (AAR) how to fix past GST invoice errors and which exchange rates to use for foreign currency. The Authority decided it could not answer these questions because they were procedural rather than related to tax classification or specific legal interpretations.
What has changed
How it worked before
Businesses often hoped the Advance Ruling process could provide a roadmap for fixing accounting mistakes or administrative oversights in their GST filings.
What has changed
The Authority clarified that it only rules on specific legal questions like tax rates or service classification. It will not provide instructions on how to correct past accounting errors or manage daily administrative tasks.
Who this affects
Any business owner seeking official guidance on how to fix past GST filing mistakes or accounting procedures.
An example
Imagine a travel agency that realized they charged the wrong GST rate on invoices for the last year. They might want to ask the AAR for a step-by-step guide on how to issue credit notes and adjust their returns. Based on this ruling, the AAR would reject their request because it is a procedural question, not a legal interpretation of the tax law.
What you should do
Do not use the Advance Ruling process to ask for help with accounting errors or procedural corrections. This ruling is not a law and only applies to the company that asked; it does not grant you permission to follow their specific situation.
If you do nothing
If you assume this ruling allows you to bypass standard correction procedures, you risk filing incorrect returns. A tax officer may reject your adjustments or impose penalties for non-compliance. Relying on an assumption rather than the law can lead to costly disputes.
The terms explained
- Advance Ruling
- A formal decision by tax authorities on how GST law applies to a specific business transaction.
- Mandate of the Authority
- The specific legal powers and duties assigned to the tax authority, which limit what they are allowed to decide.
- Not maintainable
- A legal term meaning the request does not meet the requirements to be heard or decided by the court or authority.
The ruling in detail
Authority for Advance Ruling
Odyssey Tours & Travels Pvt. Ltd.
Advance Ruling No. GOA/GAAR/5 of 2018-19 dated 22/01/2019 · Goa
Questions before the authority
- Whether they may be allowed to start the correct their invoices from September 2018 onwards.
- Whether rectification regarding past invoices can be done in the annual return supposed to be done by December 2018.
- What rate of exchange they should consider for their billing in foreign exchange?
Facts
The applicant realized they had not distributed tax amounts correctly across different States and Union Territories for the past 13 months. They sought guidance on rectifying these past invoices and the appropriate exchange rate for foreign currency billing. The applicant requested permission to adjust these errors through their annual return.
Ruling
| Question | What the authority ruled |
|---|---|
| Rectification of past invoices and annual return | Rejected Questions deemed advisory and outside the scope of section 97 |
| Foreign exchange rate for billing | Rejected Questions deemed advisory and outside the scope of section 97 |
The Authority rejected the application in its entirety. It held that the questions raised by the applicant are of an advisory nature and are not covered under the scope of section 97 of the Act.
Reasoning
The Authority determined that the applicant was seeking procedural advice rather than a ruling on the classification of goods or services or the applicability of a notification. It concluded that the questions do not fall within the **mandate of the Authority** as defined under section 97 of the CGST/GGST Act, 2017. Consequently, the application was **rejected as not maintainable**.
Provisions relied on
- Section 97 of the CGST/GGST Act, 2017
- Section 98 of the CGST/GGST Act, 2017
For the practitioner
This ruling serves as a reminder that the Advance Ruling mechanism is not a forum for seeking general procedural guidance or administrative advice on correcting past accounting errors. Practitioners should note that the Authority will **summarily reject applications** that do not pertain to the specific matters listed in section 97(2). It does not provide a pathway for rectifying historical tax distribution errors.
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/goa-gaar-5_dt.22.01.2019_ottpl.pdf
Legibility of the scan, as read: high.
Prepared 20-10-2026.
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