Maharashtra GST Advance Ruling Withdrawal: Roop Rasayan Industries Case
The Authority for Advance Ruling allowed the applicant to withdraw their request, meaning no legal decision was made on their tax questions.
- Ruling
- NO.GST-ARA-23/2022-23/B-620 Mumbai, dt. 18/11/2025
- Dated
- 18 Nov 2025
- 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
- Roop Rasayan Industries asked for a ruling on export of services.
- The company later requested to withdraw their application voluntarily.
- The Authority accepted the withdrawal without deciding on the tax merits.
In short
Roop Rasayan Industries asked the Maharashtra Authority for Advance Ruling (AAR) whether their services qualified as an export of services under the Integrated Goods and Services Tax (IGST) Act. Before the authority could decide, the company asked to withdraw their application because they found clarity elsewhere. The authority closed the case without providing any guidance on the taxability of those services.
What has changed
How it worked before
Businesses often seek an advance ruling to get a clear answer on how to tax a specific service before they file their returns.
What has changed
Nothing changed because the authority did not issue a decision. The tax status of the services in question remains exactly as it was before the application was filed.
Who this affects
Businesses that are considering filing an application for an advance ruling or those who have already filed one and are reconsidering their position.
What you should do
If you have a similar tax question, do not rely on this order for guidance, as it contains no legal interpretation. You must seek your own professional advice or file your own application if you need a binding decision for your specific business.
If you do nothing
If you assume this order provides a precedent for your own business, you risk making incorrect tax filings. A tax officer is not bound by a withdrawn application and may disagree with your interpretation, leading to potential penalties or interest charges.
The terms explained
- Advance Ruling
- A written decision provided by tax authorities to a business to clarify how tax laws apply to their specific transactions.
- Export of Services
- A specific type of supply where services are provided to a recipient located outside India, often subject to different tax rules.
- Integrated Goods and Services Tax (IGST)
- The tax levied on the supply of goods or services that take place between different states or involve imports and exports.
The ruling in detail
Authority for Advance Ruling
M/s. ROOP RASAYAN INDUSTRIES PVT. LTD.
NO.GST-ARA-23/2022-23/B-620 Mumbai, dt. 18/11/2025 · Maharashtra
Questions before the authority
- Whether the Supply of Services as specified in the facts of the case is termed as 'Export of Services' as per Section 2(6) of IGST Act, 2017?
- If not covered in (1) above, whether the same falls under the provisions of entry 12AA in Notification No.09/2017 - Integrated Tax (Rate) as notified by the Notification No.20/2019 - Integrated Tax (Rate) dt. 30/09/2019?
Facts
The applicant is engaged in the sourcing and distribution of commodities and raw materials for various industries including enamel, glass, and pharmaceuticals. They sought an advance ruling regarding the classification and taxability of their supply of services. Subsequently, the applicant requested to withdraw their application, citing clarity obtained from a High Court judgment.
Ruling
The Authority allowed the applicant to withdraw their application voluntarily and unconditionally. Consequently, the application was disposed of without addressing the merits or the specific questions raised.
Reasoning
The applicant submitted a letter dated 06.11.2025 expressing their desire to withdraw the application. The Authority, acting under the provisions of the CGST Act and MGST Act, accepted this request. As the application was withdrawn voluntarily and unconditionally, the Authority did not proceed to examine the merits of the case or provide a ruling on the questions presented.
Provisions relied on
- Section 98 of the Central Goods and Services Tax Act, 2017
- Section 98 of the Maharashtra Goods and Services Tax Act, 2017
For the practitioner
This order serves as a procedural record of the **withdrawal of an application** for an advance ruling. It provides no legal precedent or interpretation regarding the classification or taxability of the services in question. Practitioners should note that the substantive issues remain **undecided** by this authority.
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/withdrawal_order_roop_rasayan_industries_pvt_ltd-compressed_1_1.pdf
Legibility of the scan, as read: high.
Prepared 14-10-2026.
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