Mandatory GST advance ruling fee compliance renders an incomplete application non-maintainable and liable to threshold rejection.

An advance ruling application must be filed in the prescribed form with the mandatory statutory fee, and strict compliance with the fee requirement is a condition precedent to consideration. Where the prescribed fee under the Central and State GST enactments is not paid in full, the application does not satisfy the filing preconditions and is not maintainable. On that basis, the request was rejected at the threshold as liable to rejection for non-compliance with the statutory fee mandate.

---

---

Issues: Whether the advance ruling application was maintainable when the prescribed fee of Rs. 10,000 was not paid.

Analysis: The application for advance ruling had to be made in FORM GST ARA-01 and accompanied by the fee prescribed under Section 97(1) of the Central Goods and Services Tax Act, 2017 and Rule 104 of the Central Goods and Services Tax Rules, 2017, with corresponding provisions under the Gujarat Goods and Services Tax Act, 2017 and the Gujarat Goods and Services Tax Rules, 2017. Since the fee required under the two parallel enactments was not deposited in full, the application did not satisfy the statutory preconditions for consideration.

Conclusion: The application was not maintainable and was liable to rejection under Section 98(2) of the Central Goods and Services Tax Act, 2017.

Final Conclusion: The advance ruling request failed at the threshold for want of compliance with the mandatory filing fee requirement.

Ratio Decidendi: An advance ruling application must strictly comply with the prescribed form and aggregate statutory fee requirements, and non-payment of the full fee renders the application liable to rejection as non-maintainable.

---