Advance ruling jurisdiction excludes refund of accumulated input tax credit under the GST refund mechanism.

An application seeking directions on refund of accumulated input tax credit under the inverted duty structure was outside the Advance Ruling Authority's jurisdiction because refund quantification and sanction fall under the GST refund mechanism, not the limited questions listed for advance ruling. The scope of section 95(a) read with section 97(2) of the CGST Act confines advance rulings to specified matters, and refund of accumulated input tax credit under section 54 is not one of them. The Authority therefore held that such a refund request was not maintainable before it and rejected the application.

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Issues: Whether an application seeking directions on refund of accumulated input tax credit under the inverted duty structure, including refund under the category of any other ground, is maintainable before the Advance Ruling Authority.

Analysis: The application was examined in the light of the restricted scope of advance ruling under section 97(2) of the CGST Act, 2017. The questions raised related to the quantification and sanction of refund of accumulated input tax credit, which fall within the refund mechanism under section 54 of the CGST Act, 2017 and not within the matters specifically enumerated for advance ruling. Since section 95(a) read with section 97(2) confines the Authority's jurisdiction to specified questions, the refund issue was held to lie outside its remit.

Conclusion: The application was not maintainable before the Authority and was rejected.

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