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Rejection of application for Advance Ruling - Levy of GST - The appellate authority observed that the rejection of the advance ruling application was based on the investigation initiated by DGGI. The rejection did not consider the GST applicability issue directly. - The authority found that the rejection of the application lacked procedural fairness. The appellant was not provided with materials and comments forwarded by DGGI, depriving them of the opportunity to respond. Consequently, the case was remanded to the lower authority for reconsideration while ensuring the appellant's right to a fair hearing.