Advance ruling jurisdiction does not cover refund entitlement on accumulated input tax credit, especially after prior GST rejection.

AAR jurisdiction did not extend to a request framed as input tax credit admissibility but in substance seeking a ruling on refund entitlement and refund computation under Section 54(3) read with Rule 89(5). The expression "admissibility of input tax credit" was treated as not covering adjudication of refund of accumulated credit, so the questions were outside Section 97(2). The application was also barred because the refund claim had already been rejected by the jurisdictional authority, attracting Section 98(2), which prevents admission of a question already decided in proceedings under the GST law. The application was therefore rejected at the admission stage.

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Issues: Whether the applicant's questions relating to refund of accumulated input tax credit under the inverted duty structure, including GST paid on mining royalty under reverse charge, were admissible within the advance ruling jurisdiction and whether the application was barred because the refund claim had already been decided in proceedings under the GST law.

Analysis: The application, though framed with reference to input tax credit, in substance sought a ruling on refund entitlement and refund computation under Section 54(3) of the Central Goods and Services Tax Act, 2017 read with Rule 89(5) of the Central Goods and Services Tax Rules, 2017. Such questions did not fall within the matters enumerated in Section 97(2) of the Central Goods and Services Tax Act, 2017, since the expression "admissibility of input tax credit" does not extend to adjudication on refund of accumulated credit. The Authority further noted that the refund claim had already been rejected by the jurisdictional authority, attracting the bar under Section 98(2) of the Central Goods and Services Tax Act, 2017 against admitting an application on a question already decided in proceedings under the Act.

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

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