Advance ruling jurisdiction is confined to specific actual or proposed supplies; hypothetical tax queries are not admissible.

Advance ruling jurisdiction is limited to questions arising from a specific supply of goods or services undertaken or proposed by the applicant. Where an application seeks general clarification on hypothetical scenarios, without a concrete transaction, contractual arrangement, or factual matrix from the applicant's own business, it falls outside Section 95(a) and Section 97(2). Questions framed as broad tax queries or advisory issues for third parties are not admissible under the advance ruling mechanism, which is not meant to provide opinions in the abstract. The application was therefore held not maintainable and rejected without examination of the merits.

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Issues: Whether an advance ruling application is maintainable when the questions raised do not arise from any identifiable supply of goods or services undertaken or proposed to be undertaken by the applicant and instead seek general clarification on hypothetical situations.

Analysis: The statutory scheme of advance ruling is confined to questions relating to a supply of goods or services undertaken or proposed to be undertaken by the applicant. An application that merely posits hypothetical scenarios, without disclosing a concrete transaction, contractual arrangement, or factual matrix of the applicant's own business, falls outside the scope of Section 95(a) and Section 97(2). Questions framed as general tax queries or academic issues for the benefit of third parties cannot be entertained under the advance ruling mechanism, which is not intended to function as a forum for advisory opinions.

Conclusion: The application was not maintainable and was rejected as not admissible, without examination of the merits of the questions raised.

Ratio Decidendi: An advance ruling can be sought only in relation to a specific actual or proposed supply of the applicant; academic or general advisory questions unconnected with such supply are not admissible.

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