Advance ruling maintainability turns on whether the applicant is the supplier in the relevant transaction, not merely the recipient.

Advance ruling jurisdiction is confined to questions relating to a supply of goods or services, or both, undertaken or proposed to be undertaken by the applicant. Where the applicant is only the recipient of immovable property and not the supplier in the impugned transaction, the statutory precondition for maintainability is not satisfied. The Authority therefore declined to examine the taxability issue on merits and rejected the application at the threshold for want of jurisdiction.

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Issues: Whether an advance ruling application is maintainable when the applicant is a recipient of immovable property and not a person undertaking or proposing to undertake the relevant supply.

Analysis: The authority held that its jurisdiction under the advance ruling provisions extends only to matters concerning supply of goods or services or both undertaken or proposed to be undertaken by the applicant. On the facts placed before it, the applicant had purchased the shops and was seeking a ruling on the taxability of that transaction, but the applicant was not the supplier in the impugned transaction. Since the statutory condition linking the question to a supply undertaken or proposed by the applicant was not satisfied, the application did not fall within the authority's scope and could not be entertained on merits.

Conclusion: The application was not maintainable and was rejected.

Final Conclusion: The authority declined to go into the taxability question and disposed of the advance ruling request at the threshold for want of statutory maintainability.

Ratio Decidendi: An advance ruling can be entertained only where the question arises in relation to a supply of goods or services or both undertaken or proposed to be undertaken by the applicant; a recipient seeking a ruling on a transaction in which it is not the supplier falls outside that jurisdiction.

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