Chapter XVII - Advance ruling
Section 103
Section 103: Applicability of advance ruling
Section 103 identifies whom an advance ruling binds and when a change in law, facts or circumstances ends that binding effect.
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This article is for general information. Refer to the Central Goods and Services Tax Act, 2017 official text for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(1) The advance ruling pronounced by the Authority or the Appellate Authority under this Chapter shall be binding only— (a) on the applicant who had sought it in respect of any matter referred to in sub-section (2) of section 97 for advance ruling; (b) on the concerned officer or the jurisdictional officer in respect of the applicant.
(1A) The Advance Ruling pronounced by the National Appellate Authority under this Chapter shall be binding on— (a) the applicants, being distinct persons, who had sought the ruling under sub-section (1) of section 101B and all registered persons having the same Permanent Account Number issued under the Income-tax Act, 1961 (43 of 1961); (b) the concerned officers and the jurisdictional officers in respect of the applicants referred to in clause (a) and the registered persons having the same Permanent Account Number issued under the Income-tax Act, 1961 (43 of 1961).
(2) The advance ruling referred to in sub-section (1) and sub-section (1A) shall be binding unless the law, facts or circumstances supporting the original advance ruling have changed.
Introduction
A State-level advance ruling is applicant-specific. A ruling on conflicting State rulings through the national route has broader PAN-linked effect; CBIC lists the GSTAT Principal Bench as the empowered interim forum.
Key takeaways
Ordinary binding effect
An Authority or Appellate Authority ruling binds only the applicant and the concerned or jurisdictional officer in respect of that applicant.
National route
A National Appellate Authority ruling, where issued under the statutory route, has the distinct-person and same-PAN effect stated in subsection (1A).
Changed foundation
The ruling remains binding only while its underlying law, facts and circumstances remain unchanged.
Ordinary binding effect
An Authority or Appellate Authority ruling binds only the applicant and the concerned or jurisdictional officer in respect of that applicant.
National route
A National Appellate Authority ruling, where issued under the statutory route, has the distinct-person and same-PAN effect stated in subsection (1A).
Changed foundation
The ruling remains binding only while its underlying law, facts and circumstances remain unchanged.
Practical checklist
Do
- Identify who obtained the ruling.
- Compare your facts and law with the ruling’s foundation.
- Check the 2026 Principal Bench notification and the exact section 101B ruling before relying on a national-route result.
Avoid
- Assume a State-level ruling has the same PAN-wide reach as a section 101B national-route ruling.
Frequently asked questions
Does another taxpayer’s State AAR ruling automatically bind me?
No. Section 103(1) limits ordinary binding effect to the applicant and its specified officers.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026