Advance Ruling maintainability for completed transactions: application rejected because transaction was concluded before filing, so ruling unavailable.

An advance ruling under the CGST framework cannot be entertained for transactions already completed before filing; where assignment of leasehold rights, transfer of possession and full payment were concluded prior to the application, the supply is not a transaction "being undertaken or proposed to be undertaken" under Section 95(a), so questions on taxability of land development charges and entitlement to input tax credit fall outside the AAR's remit and the application is not maintainable.

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Issues: Whether an applicant can seek an advance ruling under Section 95(a) of the Central Goods and Services Tax Act, 2017 (and corresponding provisions of the APGST Act, 2017) in respect of a transaction that was fully completed before filing the application.

Analysis: The Authority examined whether the assignment of leasehold rights and associated payments constituted a supply "being undertaken or proposed to be undertaken" as required for an advance ruling under Section 95(a). The factual record shows the agreements were executed, possession transferred, and full consideration paid before filing the ARA-01 application. Since an advance ruling is statutory relief intended for supplies that are to be undertaken or are proposed, a transaction already concluded at the time of filing falls outside the statutory scope. The Authority therefore restricted its consideration to the question of maintainability and did not proceed to decide the taxcharacterization or ITC eligibility on merits.

Conclusion: The application is not maintainable because the transaction was completed prior to filing; an advance ruling cannot be sought for a completed transaction. The applicant's request for an advance ruling is accordingly rejected in favour of the Revenue.

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