Advance-ruling scrutiny must address material contentions and independently test GST exemption eligibility on the applicant's own facts.

Advance-ruling authority must specifically address the material contention raised by the applicant and independently examine eligibility on the facts and legal framework relevant to the reference. Here, the challenge concerned whether a society qualified as an educational institution entitled to exemption from GST registration and liability, despite educational activity being carried on through a special purpose vehicle. Because the impugned rulings did not directly consider the society's own objects or its asserted manner of carrying on educational activity, they were found legally unsustainable and were quashed. The matter was remanded for fresh consideration and a reasoned decision in accordance with law.

---

---

Issues: Whether the advance rulings were liable to be set aside for failing to consider the petitioner-society's contention that it was an educational institution entitled to exemption from GST registration and liability.

Analysis: The authorities rejected the claim on the footing that the actual educational activity was undertaken by the society's special purpose vehicle and not by the society itself. The challenge before the Court was that the core question was not answered independently on the basis of the society's own objects and the manner in which it carried on educational activity through that vehicle. Since the impugned rulings did not specifically address that contention or examine the society's eligibility on its own strength, the decisions were found to be legally unsustainable.

Conclusion: The impugned rulings were quashed and the matter was remanded for fresh consideration and a reasoned decision in accordance with law.

Final Conclusion: The petitioner obtained setting aside of the adverse advance rulings and a fresh adjudication on the exemption and registration question was directed.

Ratio Decidendi: An authority determining advance-ruling questions must specifically address the material contention placed before it and cannot sustain its conclusion without independently examining the assessee's eligibility on the facts and legal framework relevant to the reference.

---