Advance ruling scope under GST excludes credit set-off mechanics; application rejected as not maintainable at admission.

The advance ruling jurisdiction under Section 97(2) of the CGST Act is limited to specified questions, and a query on the procedure for setting off an already ascertained tax liability does not fall within that scope. The applicant's request concerning utilisation of SGST input tax credit for IGST liability, while SGST output tax remained unpaid and CGST credit was available, was governed by Section 49(5), Section 49A and Rule 88A rather than any admissible advance ruling issue. The application was therefore held not maintainable and rejected at the admission stage under Section 98(2).

---

---

Issues: Whether the applicant's query on utilisation of SGST input tax credit for discharging IGST liability, while SGST output liability remained unpaid and CGST credit was still available, was an admissible question for advance ruling and whether the application was liable to be rejected at the admission stage.

Analysis: The advance ruling jurisdiction is confined to the specific classes of questions enumerated in Section 97(2) of the Central Goods and Services Tax Act, 2017. The query raised did not seek a ruling on classification, notification, time or value of supply, admissibility of input tax credit, liability to pay tax, registration, or whether a transaction amounts to supply. Instead, it sought clarification on the procedure for setting off an already ascertained tax liability, which is governed by the statutory mechanism under Section 49(5), Section 49A and Rule 88A of the Central Goods and Services Tax Rules, 2017. The Authority therefore held that the issue lay outside the scope of advance ruling and was not liable for admission.

Conclusion: The application was not maintainable as an advance ruling request and was rejected under Section 98(2) of the Central Goods and Services Tax Act, 2017.

---