Advance ruling bar on repeated taxability questions blocked a fresh application on frozen peas warehousing charges.

A fresh advance ruling application on the taxability of storage or warehousing of frozen peas was held inadmissible because the same question had already been decided in the applicant's earlier ruling. Applying the statutory bar under Section 98(2) of the CGST Act, 2017 and the corresponding State provision, the AAR noted that an application cannot be admitted where the question raised is already pending or decided in the applicant's case. As the record showed a prior ruling on storage charges for frozen green peas, the new application was not entertained and no answer was given on the merits.

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Issues: Whether the fresh advance ruling application seeking a decision on taxability of storage or warehousing of frozen peas was admissible when the same question had already been decided in an earlier advance ruling.

Analysis: The application was examined in the light of the statutory bar under Section 98(2) of the CGST Act, 2017 and the corresponding State provision, which prohibits admission of an application where the question raised is already pending or decided in proceedings in the applicant's case. The record showed that the same applicant had previously obtained a ruling on the taxability of storage charges for frozen green peas, and the present questions were found to have already been answered.

Conclusion: The fresh application was not admissible and was not answered.

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