Advance-ruling jurisdiction excludes confirmation of completed arbitral-award receipts already reported under an adopted GST tax position.

Advance-ruling jurisdiction is limited to supplies being undertaken or proposed, and cannot be used to validate tax treatment already adopted for amounts received under an arbitral award. Although the permissible ruling subjects are listed separately, they do not expand this threshold requirement. Where contractual work, the award, settlement receipt and return filing had already occurred, determining the character of award components required examination of contracts, arbitral records, accounts, returns and evidence within the proper officer's adjudicatory jurisdiction. Transitional provisions apply only to a genuine upward price revision, while the earlier-law test concerns whether tax was leviable, not actually paid.

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Issues: Whether an advance-ruling application concerning amounts already received under an arbitral award, and whose tax treatment had already been adopted in returns, was maintainable under the statutory advance-ruling framework.

Analysis: An advance ruling under Section 95(a) is confined to supplies being undertaken or proposed to be undertaken. Section 97 identifies permissible subjects for a ruling but does not enlarge this jurisdictional requirement. The contractual work was completed before GST, the arbitral award had been made, the settlement amount received, and the applicant had filed returns treating the receipts as non-taxable. The application therefore sought confirmation of an already adopted tax position rather than advance certainty. Characterisation of the individual award components would require detailed scrutiny of contracts, arbitral proceedings, accounts, returns and evidence, which lies within the statutory adjudicatory jurisdiction of the proper officer. Section 142(2)(a) applies only where there is a genuine upward revision of the price of pre-GST supplies; an arbitral award cannot automatically be equated with such revision. Further, the test under Section 142(11)(a) is whether tax was leviable under the earlier law, not whether it was actually paid.

Conclusion: The advance-ruling application was not maintainable and ought not to have been entertained; no final determination was made on the GST taxability of the arbitral-award amounts.

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