Applicability of advance ruling
Section 103, CGST Act
Straight from CBIC
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Amendment history
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In one line
Section 103 makes an advance ruling BINDING only on the applicant who sought it and on the jurisdictional officer for that applicant – it is not a general precedent.
What this means in practice
The parts that actually decide cases — the things a practitioner checks first.
Binding only on the applicant and his jurisdictional officer, and only while the law and facts stand. A ruling in someone else’s case has persuasive value at best – and rulings of different State Authorities routinely conflict.
It binds the applicant too: an unfavourable ruling cannot simply be ignored, which is why the decision to apply needs care.
Questions people actually ask
Real questions we get on this provision, answered straight.
Another company got a favourable ruling on the same product. Can we rely on it?+
Not as binding authority – section 103 confines a ruling to the applicant and his officer. You can cite it as persuasive material, but a State Authority elsewhere may hold the opposite, and often has. Decide on the statutory position, not on someone else’s ruling.
How this provision is built
The skeleton, clause by clause — useful when a notice cites a specific sub-clause.
The exact words of the law
1,152 characters, uneditedReproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.
Read the full provision+
(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. 1 [(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) 2 [and sub-section (1A)] shall be binding unless the law, facts or circumstances supporting the original advance ruling have changed.
High Court cases on this section
Judgments in our index that cite this provision. Being listed does not make a case good law — it may have been appealed or distinguished since. Read it before relying on it.
What changed, and when
The amendment trail, newest first — because the version that applies to your case depends on the period.
date not stated · Inserted
Inserted by s.107 of the Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.
date not stated · Inserted
Inserted by s.107 of the Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.
Read this with
A provision rarely works alone. These are the ones it points to.
Where this comes from
Text reproduced from the Central Board of Indirect Taxes and Customs, as available on 2026-09-05. The explanation and practice notes above are GSTZone’s own, written for this hub. If you spot anything out of date, tell us and we’ll fix it — this hub is checked daily against CBIC.
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Does this apply to your case, or not?
Reading the section is one thing. Knowing whether it bites on your facts, and what it costs if it does, is another. Send us the situation – we will tell you straight, and only take it on if we can genuinely help.
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