Advance ruling jurisdiction limits prevent examination of tax invoice requirements for inter-State bauxite supplies.

The AAR held that its advance ruling jurisdiction was limited to registered persons within the State and could not extend to applicants registered in other States, so the application concerning bauxite supplies from captive mines outside Uttar Pradesh was not maintainable and was rejected. It also noted that the request concerned the requirement to issue tax invoices for each consignment under the GST law, but declined to answer that substantive question because territorial jurisdiction was absent.

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Issues: Whether the advance ruling application was maintainable before the Authority in relation to supplies of bauxite from captive mines situated outside the State, and whether the applicant was required to issue a tax invoice for each consignment in the manner sought.

Analysis: The statutory definitions of inward supply, outward supply, recipient and supplier under the Central Goods and Services Tax Act, 2017 and the corresponding Uttar Pradesh Goods and Services Tax Act, 2017 were read with the requirement in section 31(1) for issuance of tax invoice by a registered person supplying taxable goods. The Authority also noticed that its advance ruling jurisdiction under section 98 was confined to registered persons within the State and could not extend to persons registered in other States, which affected the maintainability of the application.

Conclusion: The application was held to be not maintainable before the Authority and was rejected.

Final Conclusion: The ruling declined to answer the requested advance question on merits and brought the proceedings to an end on the ground of want of jurisdiction.

Ratio Decidendi: An advance ruling authority can entertain an application only within the limits of its statutory territorial jurisdiction, and where that jurisdiction is absent the application is liable to be rejected without adjudication on the substantive tax issue.

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