Advance ruling binding effect remains limited to applicants and jurisdictional officers, preventing third-party writ challenges based on contractual consequences.

Advance rulings under the Central Goods and Services Tax Act, 2017 are described as a self-contained regime binding only on the applicant and the concerned or jurisdictional officer for that applicant. The notes state that a third party cannot rely on contractual or financial consequences to acquire standing to challenge an advance ruling or appellate advance ruling under Article 226. They further explain that where a contract only requires reimbursement of applicable GST invoiced by a contractor and does not fix classification or rate, an appellate advance ruling does not itself alter contractual liability or impose an additional GST burden. Treating it otherwise would require rewriting the contract in writ jurisdiction.

---

---

Issues: (i) Whether a person other than the applicant or the concerned/jurisdictional officer can maintain a writ petition challenging an advance ruling or appellate advance ruling under Article 226 of the Constitution of India. (ii) Whether the advance ruling imposed an additional GST liability or civil consequence on the petitioner under the contract.

Issue (i): Whether a third party has locus standi to challenge an advance ruling or appellate advance ruling.

Analysis: Sections 97 to 103 of the Central Goods and Services Tax Act, 2017 constitute a self-contained statutory scheme governing advance rulings. Under Section 103, an advance ruling is binding only on the applicant and the concerned or jurisdictional officer in respect of that applicant. The ruling is therefore a decision in personam and cannot bind or be challenged by a third party merely because contractual or financial consequences may flow from it. The general concept of an aggrieved person cannot enlarge the limited statutory binding effect of the ruling.

Conclusion: A third party who is neither the applicant nor the concerned or jurisdictional officer has no locus standi to challenge an advance ruling or appellate advance ruling under Article 226 of the Constitution of India.

Issue (ii): Whether the appellate advance ruling altered the petitioner's contractual liability or imposed an additional GST burden.

Analysis: The contract required reimbursement of applicable GST as invoiced by the contractor but did not predetermine the classification of the supply or the applicable GST rate. The appellate advance ruling did not alter any agreed contractual classification or rate. Treating the ruling as imposing an additional liability would require reading terms into, or rewriting, the contract, which is impermissible in writ jurisdiction.

Conclusion: The appellate advance ruling did not impose an additional GST liability, pecuniary burden, or civil consequence on the petitioner.

Final Conclusion: The petitioner could not invoke writ jurisdiction to challenge the advance ruling because it lacked locus standi and was not bound by the ruling. The challenge was consequently unavailable on the grounds asserted.

Ratio Decidendi: An advance ruling under the Central Goods and Services Tax Act, 2017 is binding only on the applicant and the concerned or jurisdictional officer in respect of that applicant; a third party cannot challenge it merely because contractual or financial consequences may follow.

---