Advance ruling jurisdiction cannot extend to out-of-State supplies or hypothetical future contracts under GST.

An Authority for Advance Ruling in Tamil Nadu declined to admit a request on sub-contract services for a project situated outside the State, holding that its jurisdiction is confined to matters within Tamil Nadu and that the place of supply was outside its territorial reach. It also refused to answer whether exemption would apply to unspecified future sub-contracts, since advance ruling proceedings cannot address hypothetical questions detached from concrete contractual facts. No substantive ruling on exemption was rendered, and both issues were rejected at the admission stage on jurisdictional and hypothetical grounds.

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Issues: (i) Whether the Authority had jurisdiction to rule on the applicant's request concerning sub-contract services rendered for a project situated outside Tamil Nadu. (ii) Whether an advance ruling could be given on the applicability of exemption to future sub-contracts involving unspecified transactions.

Issue (i): Whether the Authority had jurisdiction to rule on the applicant's request concerning sub-contract services rendered for a project situated outside Tamil Nadu.

Analysis: The supply was found to be rendered from Tamil Nadu to Maharashtra, and the place of supply lay outside Tamil Nadu. Since an Authority for Advance Ruling exercises jurisdiction only within the State under the relevant GST framework, the Tamil Nadu Authority could not assume jurisdiction over the question raised in respect of an inter-State transaction situated outside the State.

Conclusion: The question was not admitted for want of jurisdiction.

Issue (ii): Whether an advance ruling could be given on the applicability of exemption to future sub-contracts involving unspecified transactions.

Analysis: The request covered all future contracts without reference to specific contractual terms or activities. Such matters depend on the facts of each individual contract and cannot be answered in the abstract as hypothetical questions in advance ruling proceedings.

Conclusion: The question was not admitted as being hypothetical.

Final Conclusion: No substantive ruling on exemption was rendered, and both questions were declined at the admission stage on jurisdictional and hypothetical grounds.

Ratio Decidendi: An advance ruling authority cannot decide a question where the transaction lies outside its territorial jurisdiction, and it cannot pronounce on hypothetical future transactions divorced from specific facts.

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