Advance Ruling admissibility: only applicant centric supply questions are permissible; third party queries warrant rejection after hearing.

Authority addressed admissibility of advance ruling requests and concluded that questions must concern supplies undertaken or proposed by the applicant within the statutory categories; queries about a tenant's activities or the applicability of precedents to another person's facts fall outside the applicant centric scope and are inadmissible. After providing an opportunity to be heard and noting absence of material altering admissibility, the Authority applied the statutory power to reject applications following examination and hearing and rejected the application accordingly. The ruling emphasises that binding effect of any advance ruling remains limited to the applicant itself.

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Issues: (i) Whether the queries in the applicant's Advance Ruling application (relating to hostel accommodation being a "residential dwelling", applicability of exemption entries and related composite supply and precedent applicability) are admissible for determination under the advance ruling scheme and (ii) Whether the application is liable for rejection under Section 98(2) of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether the queries in the Advance Ruling application are admissible under the definition and scope of "advance ruling" provided in Section 95(a) read with Section 97(2) of the Central Goods and Services Tax Act, 2017.

Analysis: The Authority considered the statutory definition of advance ruling which limits rulings to matters in relation to supply of goods or services being undertaken or proposed to be undertaken by the applicant. The Authority evaluated the applicant's queries and found they primarily seek rulings on activities carried out by the applicant's tenant and on applicability of judgments to the tenant's facts. The Authority also reviewed Section 97(2) which enumerates the types of questions admissible for advance ruling and noted that applicability of case law to facts of another person does not fall within those clauses. The Authority therefore treated the queries as outside the applicant centric scope required by the statutory scheme.

Conclusion: The queries raised are not admissible under the advance ruling provisions because they do not relate to supplies undertaken or proposed to be undertaken by the applicant and fall outside the categories in Section 97(2).

Issue (ii): Whether, in view of the inadmissibility of the queries, the application is liable for rejection under Section 98(2) of the Central Goods and Services Tax Act, 2017.

Analysis: Having found the queries inadmissible, the Authority applied Section 98(2) which authorises the Authority to admit or reject an application after examination and hearing. The Authority noted that an opportunity of hearing was given, the applicant's representatives had an opportunity to submit further material but did not furnish supporting documents that would alter admissibility, and that Section 103(1) limits the binding effect of any ruling to the applicant itself. On these bases the Authority concluded that the application did not qualify for admission and therefore must be rejected under the statutory provision.

Conclusion: The application is rejected under Section 98(2) of the Central Goods and Services Tax Act, 2017.

Ratio Decidendi: An advance ruling is admissible only where the question relates to supply of goods or services being undertaken or proposed to be undertaken by the applicant within the categories set out in Section 97(2); questions concerning activities of a third party or applicability of precedents to another person's facts are outside the statutory scope and warrant rejection of the application under Section 98(2).

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