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

Q: What is the National Appellate Authority for Advance Ruling (NAAR)?

NAAR is the national-level appellate body under Section 101A CGST Act 2017 that hears appeals against conflicting advance rulings from AAAR bodies in two or more states. From April 2026, the GSTAT Principal Bench at New Delhi will serve as NAAR.

Q: When will NAAR become operational?

The 56th GST Council meeting (03 September 2025) recommended that the GSTAT Principal Bench act as NAAR from April 2026 . Finance Minister Sitharaman confirmed this at the GSTAT launch on 24 September 2025. Specific operational notifications are awaited.

Q: Can I appeal any AAAR order to NAAR?

No. Under Section 101B CGST Act , an appeal to NAAR lies only where conflicting advance rulings have been given by the AAAR in two or more states or union territories. An adverse ruling from one state alone is not appealable to NAAR - the remedy in such cases is a High Court writ under Article 226.

Q: What is the time limit for a NAAR appeal?

30 days from the date of the AAAR order under Section 101B . Condonation of up to 30 additional days may be granted on sufficient cause. Total outer limit: 60 days.

Q: What is the difference between AAR, AAAR, and NAAR?

AAR (Section 96) is the state-level first authority that pronounces advance rulings. AAAR (Section 99) is the state-level appellate authority. NAAR (Section 101A) is the national authority that resolves conflicts between AAAR rulings of different states - from April 2026, housed at the GSTAT Principal Bench.

Q: Is pre-deposit required for a NAAR appeal?

No pre-deposit in the Section 112(8) sense. The fee for filing a NAAR appeal is Rs 10,000 under CGST (plus state fee). This is significantly lower than the 10% pre-deposit required for GSTAT appeals under Section 112.

Q: What form is used for a NAAR appeal?

Form GST ARA-03 is the prescribed form under the CGST Rules. Once NAAR is operational at the GSTAT Principal Bench, filing may migrate to the GSTAT e-filing portal .

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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 supported by Subham Jhunjhunwala - CA Finalist, Accounting & Tax Professional

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Overview What Is NAAR Who Should File Our Services 6-Step Process Documents Fees Why Patron NAAR vs GSTAT vs HC Legal Framework FAQs

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.

Parameter	Details
Appellate Body	National Appellate Authority for Advance Ruling (NAAR) at GSTAT Principal Bench
Governing Law	Section 101A and Section 101B CGST Act 2017
Jurisdiction	Conflicting AAAR rulings in 2+ states only
Forum	GSTAT Principal Bench, New Delhi (from April 2026)
Appeal Form	Form GST ARA-03
Time Limit	30 days from AAAR order (condonation up to 30 additional days)
Fee	Rs 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 Subham Jhunjhunwala.

Accounting & Tax Professional

Subham Jhunjhunwala

CA Finalist | Graduate

CA Finalist Accounting & Taxation GST & Compliance

Subham Jhunjhunwala is a CA Finalist and Accounting & Tax Professional at Patron Accounting LLP, focused on accounting, taxation, and compliance. He works alongside the firm's CA and CS team on GST and GSTAT appeal matters.

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 → 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

Service	What We Do
Conflicting Ruling Assessment	Comprehensive 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 Filing	Preparation 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. Writ	Where conflicting rulings do not exist but the AAAR order is adverse, advise on High Court writ under Article 226
Hearing Representation	Attend and argue NAAR appeals before the GSTAT Principal Bench in New Delhi
Pre-Emptive Advance Ruling Strategy	Advise multi-state businesses on structuring advance ruling applications to minimise the risk of conflicting rulings
Post-Ruling Implementation	Assist 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

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

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 sales@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

Subham Jhunjhunwala 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 Subham Jhunjhunwala, 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 Component	Amount
NAAR Appeal Fee (CGST)	Rs 10,000
NAAR Appeal Fee (SGST)	Rs 10,000 (respective state)
Pre-Deposit	Not applicable - NAAR appeals under Section 101B do not carry the 10% pre-deposit of Section 112(8)
Patron Accounting Professional Fees	Starting 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.

Feature	NAAR Appeal (S.101B)	GSTAT Appeal (S.112)
Subject Matter	Conflicting advance rulings only	Demand, penalty, ITC, refund orders
Pre-Deposit	No pre-deposit - Rs 10,000 fee only	10% of disputed tax + cap Rs 20 crore
Limitation	30 days from AAAR order	3 months from order communication
Forum	Principal Bench (from April 2026)	State Bench or Principal Bench
Form	Form GST ARA-03	Form 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

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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.

Specialist Support

Subham Jhunjhunwala works with the firm's CA and CS team on 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.

Firm-Backed Support

Backed by Patron Accounting's ICAI and ICSI registered CA and CS team.

Patron Accounting Scale

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

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

Feature	NAAR Appeal (S.101B)	GSTAT Appeal (S.112)	HC Writ (Art.226)
Trigger	Conflicting AAAR rulings in 2+ states	Adverse order from Commissioner Appeals	Jurisdictional error, no NAAR/GSTAT remedy
Time Limit	30 days from AAAR order	3 months from order	Reasonable time
Pre-Deposit	Rs 10,000 fee only	10% of disputed tax (cap Rs 20 crore)	None
Forum	Principal Bench only	State/Principal Bench	Jurisdictional HC
Scope	Classification/interpretation harmonisation	Full appellate review on facts and law	Constitutional 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.

NAAR and Advance Ruling Legal Framework

Provision	Section / Reference	Key Requirement
AAR Constitution	Section 96 CGST Act 2017	State-level body - pronounces advance rulings
AAR Scope	Section 97(2) CGST Act	Classification, rate, place of supply, exemption, ITC eligibility, valuation, liability
Appeal to AAAR	Section 100 CGST Act	30 days from AAR order - Form GST ARA-02
AAAR Constitution	Section 99 CGST Act	State-level appellate body for advance rulings
NAAR Constitution	Section 101A CGST Act	National body for conflicting rulings - effective 01-01-2020 (Finance Act 2019)
NAAR Appeal	Section 101B CGST Act	Only for conflicting AAAR rulings in 2+ states - Form GST ARA-03
NAAR Limitation	Section 101B	30 days from AAAR order - condonation 30 additional days
NAAR at GSTAT	56th GST Council (03-09-2025)	Principal Bench = NAAR from April 2026
Advance Ruling Binding	Section 103 CGST Act	Binding on applicant and jurisdictional officer only
Ruling Void	Section 104 CGST Act	Ruling obtained by fraud or misrepresentation is void ab initio

Frequently Asked Questions

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

NAAR is the national-level appellate body under Section 101A CGST Act 2017 that hears appeals against conflicting advance rulings from AAAR bodies in two or more states. From April 2026, the GSTAT Principal Bench at New Delhi will serve as NAAR.

When will NAAR become operational?

The 56th GST Council meeting (03 September 2025) recommended that the GSTAT Principal Bench act as NAAR from April 2026. Finance Minister Sitharaman confirmed this at the GSTAT launch on 24 September 2025. Specific operational notifications are awaited.

Can I appeal any AAAR order to NAAR?

No. Under Section 101B CGST Act, an appeal to NAAR lies only where conflicting advance rulings have been given by the AAAR in two or more states or union territories. An adverse ruling from one state alone is not appealable to NAAR - the remedy in such cases is a High Court writ under Article 226.

What is the time limit for a NAAR appeal?

30 days from the date of the AAAR order under Section 101B. Condonation of up to 30 additional days may be granted on sufficient cause. Total outer limit: 60 days.

What is the difference between AAR, AAAR, and NAAR?

AAR (Section 96) is the state-level first authority that pronounces advance rulings. AAAR (Section 99) is the state-level appellate authority. NAAR (Section 101A) is the national authority that resolves conflicts between AAAR rulings of different states - from April 2026, housed at the GSTAT Principal Bench.

Is pre-deposit required for a NAAR appeal?

No pre-deposit in the Section 112(8) sense. The fee for filing a NAAR appeal is Rs 10,000 under CGST (plus state fee). This is significantly lower than the 10% pre-deposit required for GSTAT appeals under Section 112.

What happens after NAAR passes an order?

The NAAR order harmonises the conflicting rulings and creates a binding ruling applicable pan-India on the question at issue. It supersedes the conflicting AAAR orders. Further appeal lies to the High Court on substantial questions of law.

What form is used for a NAAR appeal?

Form GST ARA-03 is the prescribed form under the CGST Rules. Once NAAR is operational at the GSTAT Principal Bench, filing may migrate to the GSTAT e-filing portal.

Quick AnswersWhen 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.

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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 is supported by Subham Jhunjhunwala, CA Finalist and Accounting & Tax Professional, working alongside the firm's CA and CS team on 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

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Tamil Nadu + Puducherry

Uttar Pradesh (Central)

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Content Created: 16 March 2026 | Last Updated: 16 March 2026 | 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.

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

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NAAR Advance Ruling Appeal - Overview

Subham Jhunjhunwala

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

Who Should File a NAAR Appeal at GSTAT?

Our NAAR Advisory and Appeal Services

Identify Conflicting Rulings

Verify NAAR Jurisdiction Under Section 101B

Prepare Form GST ARA-03

File Within 30 Days of AAAR Order

Attend Hearing Before GSTAT Principal Bench

Implement Harmonised Ruling Across States

NAAR Appeal Document Checklist

Common Challenges and Our Approach

Narrow Jurisdictional Scope of NAAR

Identifying What Constitutes a 'Conflicting' Ruling

Transition Uncertainty - April 2026 Operationalisation

NAAR Appeal Fees, Pre-Deposit, and Engagement Terms

Why Choose Patron Accounting for NAAR Appeals

Multi-State Regulatory Expertise

Specialist Support

First-Mover in NAAR Advisory

Firm-Backed Support

Patron Accounting Scale

Trusted by Businesses Across India

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

Related GSTAT and Advance Ruling Services

NAAR and Advance Ruling Legal Framework

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

When will NAAR become operational?

Can I appeal any AAAR order to NAAR?

What is the time limit for a NAAR appeal?

What is the difference between AAR, AAAR, and NAAR?

Is pre-deposit required for a NAAR appeal?

What happens after NAAR passes an order?

What form is used for a NAAR appeal?

Quick Answers

30-Day NAAR Appeal Deadline - Act Now

Resolve Conflicting Advance Rulings at NAAR - Contact Patron Accounting Today

GSTAT State Bench Locations Across India