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GSTAT Advance Ruling Appeal (NAAR): Resolve Conflicting GST Rulings at GSTAT

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Dispute Type: Conflicting advance rulings by AAAR in two or more states

Forum: GSTAT Principal Bench at New Delhi acts as NAAR from April 2026

Limitation: Appeal within 30 days of AAAR order under Section 101B CGST Act

Specialist: GSTAT matters handled by Advocate Surbhi Premi - Former Partner, LKS

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We had conflicting classification rulings across three states on our cloud product. Patron Accounting's GSTAT team mapped every ruling, identified the exact points of conflict, and built a NAAR-ready case file. The depth was outstanding.
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Patron Accounting's GSTAT practice is exceptional. Their team understood the complexity of our multi-state AAAR rulings instantly and provided clear, actionable guidance on NAAR options.
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Surbhi Premi's expertise in indirect tax and her LKS background gave us complete confidence. The pre-deposit clarification alone saved us significant working capital concerns we had about the NAAR appeal process.
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Patron Accounting's GSTAT team is ahead of the curve on NAAR. They briefed us on the April 2026 transition well before other advisors were even aware. That forward-looking approach is invaluable for our business planning.
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NAAR Advance Ruling Appeal - Overview

TL;DR: The National Appellate Authority for Advance Ruling (NAAR) under Section 101A CGST Act 2017 resolves conflicting advance rulings from different state AAAR bodies. From April 2026, the GSTAT Principal Bench at New Delhi serves as NAAR. Appeals are filed in Form GST ARA-03 within 30 days of the AAAR order. Patron Accounting advises multi-state businesses on NAAR strategy.

ParameterDetails
Appellate BodyNational Appellate Authority for Advance Ruling (NAAR) at GSTAT Principal Bench
Governing LawSection 101A and Section 101B CGST Act 2017
JurisdictionConflicting AAAR rulings in 2+ states only
ForumGSTAT Principal Bench, New Delhi (from April 2026)
Appeal FormForm GST ARA-03
Time Limit30 days from AAAR order (condonation up to 30 additional days)
FeeRs 10,000 under CGST (no pre-deposit)

The National Appellate Authority for Advance Ruling (NAAR) is a long-awaited mechanism to resolve one of the most persistent challenges under GST - conflicting advance rulings pronounced by different state-level Appellate Authorities for Advance Ruling (AAAR). Introduced by Section 101A CGST Act 2017 (effective 01-01-2020 via Finance Act 2019), the NAAR was never separately constituted as an independent body.

That changed with the 56th GST Council meeting on 03 September 2025, which recommended that the GSTAT Principal Bench at New Delhi serve as the National Appellate Authority for Advance Ruling from April 2026. Finance Minister Nirmala Sitharaman confirmed this at the GSTAT launch on 24 September 2025, stating that the Principal Bench makes GSTAT a comprehensive forum for all GST disputes - both before and after initiation of proceedings.

Patron Accounting provides dedicated advisory and representation services for NAAR advance ruling appeals at the GSTAT Principal Bench, led by of-counsel Surbhi Premi.

Surbhi Premi - Advocate and Chartered Accountant, Of-Counsel to Patron Accounting
Of-Counsel - GSTAT Practice Lead

Surbhi Premi

Advocate & Chartered Accountant | Diploma in IFRS (ACCA, UK)

Former Partner, Lakshmikumaran & Sridharan 15+ Years GST, Customs & FTP Goldman Sachs Alumni 500+ Large Domestic & MNC Clients

Surbhi Premi led the Indirect Tax practice at Lakshmikumaran & Sridharan as Partner and served on LKS Team Velocity - a national GST task force handling high-sensitivity, high-impact industry matters. Her background at Goldman Sachs brings a unique blend of tax, risk, and international business understanding. A renowned ICAI faculty member and keynote speaker, her methodical approach combined with deep domain knowledge enables her to provide viable, holistic, and tax-efficient solutions for complex GST litigation and advance ruling disputes.

Financial Express Hindu Business Line India Business Law Journal Taxsutra TIOL VIL

What Is the National Appellate Authority for Advance Ruling (NAAR)?

Definition: The National Appellate Authority for Advance Ruling (NAAR) is the national-level appellate body constituted under Section 101A of the Central Goods and Services Tax Act 2017 to hear appeals under Section 101B against conflicting advance rulings pronounced by Appellate Authorities for Advance Ruling (AAAR) in two or more states or union territories.

The NAAR was introduced by the Finance Act 2019 (effective 01-01-2020) to address the problem of divergent interpretations across states - where the same transaction or classification question received different rulings from AAR and AAAR bodies in different states. Under Section 101B, an appeal lies to the NAAR only where conflicting advance rulings have been pronounced by the Appellate Authorities of two or more states or union territories.

NAAR vs GSTAT Appellate Jurisdiction: The NAAR under Section 101A is fundamentally different from the GSTAT appellate jurisdiction under Section 112 - NAAR hears appeals only against conflicting AAAR rulings from multiple states (a narrow, policy-level jurisdiction), while GSTAT hears appeals against adverse orders of the first appellate authority on all GST matters including demand, penalty, refund, and ITC disputes (a broad, fact-finding jurisdiction).

Dual Function of the Principal Bench: From April 2026, the GSTAT Principal Bench at New Delhi will serve dual functions - as the Principal Bench of the Appellate Tribunal for place of supply disputes and matters of national importance under Section 109(7), and as the National Appellate Authority for Advance Ruling under Section 101A for conflicting advance rulings.

Key Terms:

  • NAAR - National Appellate Authority for Advance Ruling (Section 101A CGST Act)
  • AAR - Authority for Advance Ruling (Section 96 CGST Act)
  • AAAR - Appellate Authority for Advance Ruling (Section 99 CGST Act)
  • Section 101B - Enables appeals to NAAR for conflicting rulings in 2+ states
  • Conflicting Ruling - Divergent AAAR rulings on the same question across states
  • Distinct Person - Entity registered in multiple states under Section 25 CGST Act
AAR State A AAR State B AAAR State A AAAR State B NAAR Principal Bench ⚠ Conflict AAR → AAAR → NAAR Appeal Hierarchy

Who Should File a NAAR Appeal at GSTAT?

A NAAR appeal is relevant for any person who has received conflicting advance rulings from the AAAR in two or more states under Section 101B CGST Act 2017. This typically affects:

  • Multi-state businesses (distinct persons under Section 25): A company registered in Maharashtra and Karnataka may receive contradictory classification rulings from the respective state AAARs - one classifying a supply as goods at 18% and the other as services at 12%.
  • Pan-India service providers: IT companies, logistics firms, and consultancies operating across multiple states may face divergent rulings on place of supply, intermediary classification, or exemption eligibility.
  • Manufacturers with multi-state operations: Classification disputes (HSN code), ITC eligibility, and valuation methodology rulings that differ across states.

The appeal must be filed within 30 days of the AAAR order in Form GST ARA-03 under Section 101B CGST Act. The AAAR may condone delay up to an additional 30 days on sufficient cause.

Our NAAR Advisory and Appeal Services

ServiceWhat We Do
Conflicting Ruling AssessmentComprehensive analysis of AAAR orders across states to determine whether the rulings qualify as 'conflicting' under Section 101B - the jurisdictional threshold for NAAR appeal
NAAR Appeal FilingPreparation and filing of Form GST ARA-03 before the GSTAT Principal Bench, including detailed grounds of appeal and comparative analysis of conflicting rulings
Strategic Advisory - Appeal vs. WritWhere conflicting rulings do not exist but the AAAR order is adverse, advise on High Court writ under Article 226
Hearing RepresentationAttend and argue NAAR appeals before the GSTAT Principal Bench in New Delhi
Pre-Emptive Advance Ruling StrategyAdvise multi-state businesses on structuring advance ruling applications to minimise the risk of conflicting rulings
Post-Ruling ImplementationAssist with implementing NAAR decisions across all registered states and ensuring compliance with the harmonised ruling
Our Process

6 Steps to File a NAAR Advance Ruling Appeal

Our streamlined process for filing and representing your NAAR appeal at the GSTAT Principal Bench

Step 1

Identify Conflicting Rulings

Compile and compare advance rulings from AAAR bodies in two or more states on the same or similar question. Document the specific points of divergence - this is the jurisdictional basis for the NAAR appeal.

Multi-state AAAR order comparison Divergence points documented
≠
Compare Rulings 01
Step 2

Verify NAAR Jurisdiction Under Section 101B

Confirm that the appeal qualifies under Section 101B - conflicting rulings by AAAR in two or more states or union territories. If the rulings are not conflicting (merely adverse), NAAR jurisdiction does not arise - the remedy is a High Court writ.

Section 101B jurisdiction check Alternative remedy assessment
Jurisdiction Verified 02
Step 3

Prepare Form GST ARA-03

Draft the appeal form with detailed comparative analysis of the conflicting rulings, the question of law or classification at issue, and the grounds on which a harmonised ruling is sought.

Comparative analysis drafted Legal grounds prepared
ARA-03
Form Prepared 03
Step 4

File Within 30 Days of AAAR Order

File Form GST ARA-03 before the GSTAT Principal Bench at New Delhi within 30 days of the AAAR order under Section 101B. An application for condonation of delay up to 30 additional days may be filed on sufficient cause.

30-day deadline tracked Rs 10,000 fee paid
Appeal Filed 04
Step 5

Attend Hearing Before GSTAT Principal Bench

The NAAR (Principal Bench) will hear both parties and pass an order within 90 days of filing under Section 101B. The ruling must be passed by at least 2 members including 1 judicial member.

Expert representation at New Delhi 90-day order timeline
Hearing Attended 05
Step 6

Implement Harmonised Ruling Across States

The NAAR order resolves the conflict and creates a binding ruling applicable across all states where the conflicting rulings existed. Ensure compliance in all registered jurisdictions.

Pan-India binding ruling Multi-state compliance ensured
Harmonised
Ruling Implemented 06

NAAR Appeal Document Checklist

  • Copies of all conflicting AAAR orders from two or more states
  • Copies of underlying AAR orders
  • Original advance ruling applications (Form GST ARA-01) filed in each state
  • Completed Form GST ARA-03
  • Comparative analysis of conflicting rulings highlighting specific divergences
  • Supporting CBIC circulars, notifications, and HSN explanatory notes
  • Relevant HC/SC judgments on the classification or question at issue
  • GSTIN details for all registrations across states (distinct person under Section 25)
  • Power of attorney or Vakalatnama for authorised representative
  • Fee payment proof (Rs 10,000 under CGST)

Download our NAAR Appeal Checklist - email info@patronaccounting.com or call +91 945 945 6700.

Common Challenges and Our Approach

Narrow Jurisdictional Scope of NAAR

The most critical challenge is that Section 101B limits NAAR appeals to conflicting rulings only. If a business receives an adverse AAAR ruling in one state but no conflicting ruling in another state, NAAR jurisdiction does not arise. In our experience advising multi-state businesses, this gap leaves many taxpayers without an appellate remedy against AAAR orders. Patron Accounting advises on alternative strategies including High Court writ petitions and proactive advance ruling applications in multiple states to create the jurisdictional basis for NAAR.

Identifying What Constitutes a 'Conflicting' Ruling

Surbhi Premi notes that not every difference between two state rulings qualifies as a 'conflict' under Section 101B. The rulings must take contradictory positions on the same or substantially similar question - not merely different approaches to related but distinct questions. Patron Accounting conducts a rigorous comparative analysis before recommending the NAAR route.

Transition Uncertainty - April 2026 Operationalisation

Across the matters we have assessed for NAAR readiness, a key practical concern is the transition mechanism. The 56th GST Council recommended NAAR activation from April 2026 at the Principal Bench, but specific operational rules, forms, and filing procedures for NAAR appeals at GSTAT are still being finalised. Patron Accounting monitors all gazette notifications and GSTAT portal updates to ensure timely filing when the window opens.

Illustrative Scenario: A technology company with registrations in Maharashtra and Karnataka sought advance rulings on the classification of a cloud-based subscription service. The Maharashtra AAAR classified it as 'information technology software service' at 18% GST. The Karnataka AAAR classified the same service as 'online information and database access or retrieval (OIDAR)' attracting IGST under a different head. Patron Accounting's GSTAT team, led by of-counsel Surbhi Premi, compiled both AAAR orders, prepared a detailed comparative analysis establishing the conflict on classification, and is advising on filing a NAAR appeal before the GSTAT Principal Bench once operationalised in April 2026 - seeking a harmonised classification ruling applicable pan-India.

NAAR Appeal Fees, Pre-Deposit, and Engagement Terms

Critical Clarification: The pre-deposit framework under Section 112(8) CGST Act applies to appeals against orders of the first appellate authority. NAAR appeals under Section 101B are governed by a separate advance ruling appellate framework with no pre-deposit requirement.

Fee ComponentAmount
NAAR Appeal Fee (CGST)Rs 10,000
NAAR Appeal Fee (SGST)Rs 10,000 (respective state)
Pre-DepositNot applicable - NAAR appeals under Section 101B do not carry the 10% pre-deposit of Section 112(8)
Patron Accounting Professional FeesStarting from INR 49,999 (Exl GST and Govt. Charges)

All fees listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on volume and complexity of work.

FeatureNAAR Appeal (S.101B)GSTAT Appeal (S.112)
Subject MatterConflicting advance rulings onlyDemand, penalty, ITC, refund orders
Pre-DepositNo pre-deposit - Rs 10,000 fee only10% of disputed tax + cap Rs 20 crore
Limitation30 days from AAAR order3 months from order communication
ForumPrincipal Bench (from April 2026)State Bench or Principal Bench
FormForm GST ARA-03Form GST APL-05

All fees listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on volume and complexity of work.

Assess Your NAAR Appeal Options - Speak to Our GSTAT Team

Why Choose Patron Accounting for NAAR Appeals

Multi-State Regulatory Expertise

Deep experience in comparative analysis of state-level advance rulings on classification, valuation, and exemption issues across jurisdictions.

Of-Counsel Depth

Surbhi Premi's partnership at Lakshmikumaran and Sridharan - with pan-India indirect tax practice - provides unique insight into how different state AAAR bodies approach the same questions.

First-Mover in NAAR Advisory

With NAAR becoming operational from April 2026, Patron Accounting is among the earliest firms to develop a dedicated NAAR appeal advisory service.

Published Thought Leadership

Surbhi Premi is published in the Financial Express, Hindu Business Line, India Business Law Journal, Taxsutra, TIOL, and VIL.

Patron Accounting Scale

10,000+ businesses served, 4.9 Google rating, 15+ years, offices in Pune, Mumbai, Delhi, and Gurugram.

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Businesses Served
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Google Rating
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Years Experience

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting provides NAAR appeal advisory and representation at the GSTAT Principal Bench in New Delhi - the exclusive forum for NAAR matters.

NAAR vs GSTAT Appeal vs High Court Writ - When to Use Each

FeatureNAAR Appeal (S.101B)GSTAT Appeal (S.112)HC Writ (Art.226)
TriggerConflicting AAAR rulings in 2+ statesAdverse order from Commissioner AppealsJurisdictional error, no NAAR/GSTAT remedy
Time Limit30 days from AAAR order3 months from orderReasonable time
Pre-DepositRs 10,000 fee only10% of disputed tax (cap Rs 20 crore)None
ForumPrincipal Bench onlyState/Principal BenchJurisdictional HC
ScopeClassification/interpretation harmonisationFull appellate review on facts and lawConstitutional remedies

A NAAR appeal under Section 101B is a narrow, policy-level remedy available only when conflicting AAAR rulings exist across states - unlike a GSTAT appeal under Section 112 which provides full fact-finding appellate review of demand, penalty, and ITC orders, or a High Court writ under Article 226 which addresses jurisdictional and constitutional infirmities. If an adverse AAAR ruling exists in only one state with no conflicting ruling elsewhere, NAAR jurisdiction does not arise and the remedy lies with the High Court.

Related GSTAT and Advance Ruling Services

Patron Accounting offers end-to-end GST litigation and appeal support. Explore our related GSTAT services:

NAAR and Advance Ruling Legal Framework

ProvisionSection / ReferenceKey Requirement
AAR ConstitutionSection 96 CGST Act 2017State-level body - pronounces advance rulings
AAR ScopeSection 97(2) CGST ActClassification, rate, place of supply, exemption, ITC eligibility, valuation, liability
Appeal to AAARSection 100 CGST Act30 days from AAR order - Form GST ARA-02
AAAR ConstitutionSection 99 CGST ActState-level appellate body for advance rulings
NAAR ConstitutionSection 101A CGST ActNational body for conflicting rulings - effective 01-01-2020 (Finance Act 2019)
NAAR AppealSection 101B CGST ActOnly for conflicting AAAR rulings in 2+ states - Form GST ARA-03
NAAR LimitationSection 101B30 days from AAAR order - condonation 30 additional days
NAAR at GSTAT56th GST Council (03-09-2025)Principal Bench = NAAR from April 2026
Advance Ruling BindingSection 103 CGST ActBinding on applicant and jurisdictional officer only
Ruling VoidSection 104 CGST ActRuling obtained by fraud or misrepresentation is void ab initio

Frequently Asked Questions

Quick Answers

When does NAAR start?
GSTAT Principal Bench acts as NAAR from April 2026 per 56th GST Council recommendation.
What is the NAAR appeal deadline?
30 days from AAAR order under Section 101B. Condonation up to 30 additional days.
Who can file a NAAR appeal?
Any person affected by conflicting AAAR rulings in two or more states.
Is there a pre-deposit?
No - only Rs 10,000 filing fee under CGST.
Where is NAAR located?
GSTAT Principal Bench at New Delhi.
Can a single adverse ruling be appealed to NAAR?
No - conflicting rulings from 2+ states are required. Single adverse ruling remedy is HC writ.

30-Day NAAR Appeal Deadline - Act Now

Limitation Urgency: Appeals to the National Appellate Authority for Advance Ruling under Section 101B CGST Act must be filed within 30 days of the AAAR order. Condonation up to 30 additional days on sufficient cause. Beyond 60 days, the right to appeal to NAAR is permanently lost.

The 30-day window from AAAR order is the shortest limitation in the GST appellate framework. Multi-state businesses receiving AAAR orders should immediately assess whether conflicting rulings exist.

Contact Patron Accounting immediately: +91 945 945 6700 | WhatsApp Us

Resolve Conflicting Advance Rulings at NAAR - Contact Patron Accounting Today

The activation of the National Appellate Authority for Advance Ruling (NAAR) at the GSTAT Principal Bench from April 2026 addresses one of the most fundamental structural gaps in the GST framework - the absence of a mechanism to resolve conflicting advance rulings across states. For multi-state businesses that have faced divergent interpretations on classification, exemption, or valuation from different state AAAR bodies, the NAAR under Section 101A CGST Act 2017 provides the first statutory path to a harmonised, nationally binding ruling.

Patron Accounting's GSTAT practice, led by of-counsel Advocate Surbhi Premi - former Partner at Lakshmikumaran and Sridharan and a specialist in GST, Customs, and Foreign Trade Policy - brings over 15 years of indirect tax litigation depth to every GSTAT engagement. The 30-day limitation under Section 101B, the narrow jurisdictional scope, and the forthcoming operational transition at the GSTAT Principal Bench make expert advisory essential.

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GSTAT State Bench Locations Across India

With 32 State Benches, GSTAT allows you to file your appeal at the bench for your jurisdiction — Patron Accounting represents clients across all benches.

GSTAT State Bench Locations

Select your bench location to know jurisdiction districts and filing procedure

Vijayawada
Andhra Pradesh
Patna
Bihar
Raipur
Chhattisgarh
New Delhi
Delhi (NCT)
Mumbai
Goa + Maharashtra
Pune
Goa + Maharashtra
Nagpur
Maharashtra (Vidarbha)
Ahmedabad
Gujarat
Surat
Gujarat
Gurugram
Haryana
Shimla
Himachal Pradesh
Ranchi
Jharkhand
Bangalore
Karnataka
Dharwad
Karnataka (North)
Kochi
Kerala + Lakshadweep
Indore
Madhya Pradesh
Cuttack
Odisha
Chandigarh
Punjab + Chandigarh UT
Jalandhar
Punjab
Jaipur
Rajasthan
Jodhpur
Rajasthan (West)
Chennai
Tamil Nadu + Puducherry
Madurai
Tamil Nadu (South)
Hyderabad
Telangana
Lucknow
Uttar Pradesh
Varanasi
Uttar Pradesh (East)
Prayagraj
Uttar Pradesh (Central)
Dehradun
Uttarakhand
Kolkata
WB + Sikkim + A&N
Siliguri
West Bengal (North)
Guwahati
Assam + NE States
Srinagar
J&K + Ladakh

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End-to-end GST litigation and appeal support across all forums

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India
Principal Bench Representation
New Delhi
Pre-Deposit Advisory
India
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India
e-Filing Portal Assistance
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Anti-Profiteering Appeal
India

Content Created: 16 March 2026  |  Last Updated:  |  Next Review: 16 June 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed every 3 months or when triggered by: NAAR activation gazette notification, GSTAT portal updates for Form GST ARA-03 migration, CBIC circulars on advance ruling appeals, significant HC/SC judgments on conflicting rulings, or changes to Section 101A/101B CGST Act.

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