Advance ruling scope limited to specified CGST matters; documentary sufficiency and endorsement questions were held non-maintainable.

An advance ruling under the CGST Act is maintainable only on matters expressly covered by section 97(2). Questions confined to whether documents such as the LOA, eligibility certificates, or invoices are sufficient to prove supplies for authorised operations, or whether endorsement by the Specified Officer is mandatory for DTA-to-SEZ and intra-SEZ transactions, do not fall within those permitted categories. As the request did not concern classification, notification applicability, time or value of supply, input tax credit, tax liability, registration, or whether an activity constitutes a supply, it was held to be outside the ruling authority's jurisdiction and no merits ruling was given.

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Issues: Whether the three questions seeking a ruling on the documentary sufficiency for proving supplies for authorized operations and the need for invoice endorsement in DTA-to-SEZ and intra-SEZ transactions fell within the scope of advance ruling under section 97 of the CGST Act, 2017.

Analysis: The questions were confined to whether LOA, eligibility certificates, and other documents were sufficient, or whether endorsement by the Specified Officer was mandatory. Such questions did not concern classification, applicability of a notification, time or value of supply, input tax credit, liability to pay tax, registration, or whether an activity amounted to a supply. They were therefore outside the statutory matters on which an advance ruling could be sought.

Conclusion: The questions were held to be outside the ambit of section 97 of the CGST Act, 2017, and no ruling was given on the merits.

Final Conclusion: The application was not entertained on jurisdictional grounds, leaving the substantive GST and SEZ documentary issues unanswered.

Ratio Decidendi: An advance ruling can be given only on matters expressly covered by section 97(2) of the CGST Act, 2017, and a request confined to documentary sufficiency or procedural endorsement requirements is not maintainable where it does not fall within those categories.

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