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Section 100 of the CGST Act, 2017

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GST›CGST Act, 2017›Chapter XVII, Advance Ruling

At a glance

Entitlement and conditions

100(3)Use the prescribed form, fee and verification.

Bars, duties and time limits

100(2)File within thirty days of communication; the Appellate Authority may allow up to thirty further days if sufficient cause prevented timely filing.

Procedure, powers and definitions

100(1)The concerned officer, jurisdictional officer or applicant aggrieved by a ruling under section 98(4) may appeal.
100The law does not settle what makes a person aggrieved, whether that requirement also qualifies officers, or which communication date applies when recipients receive the ruling on different dates.

The concerned officer, jurisdictional officer or an aggrieved applicant can appeal an advance ruling to the Appellate Authority. The ordinary filing period is thirty days from communication. Sufficient cause can justify a further period of no more than thirty days. The appeal must satisfy the prescribed form, fee and verification requirements; differing communication dates remain an unresolved timing issue.^[1]

Quick facts

Section 100, CGST Act, 2017

Appeal to Appellate Authority

Provision
Act	Central Goods and Services Tax Act, 2017
Chapter	XVII, Advance Ruling
Section title	Appeal to Appellate Authority
In force from	1 July 2017^[1]
Amendments
Last amendment	1 July 2017: brought section 100 into force (none — the source's own enforcement note, not an amendment footnote)
Amendments	1 footnote in the CBIC text (table)
Related provisions
Rules	Rule 26, Rule 106, Rule 107A of the CGST Rules, 2017
Sections	49, 95, 98, 99, 101
Structure 100(1)Who may appeal and against what 100(2)The thirty days for filing the appeal the proviso to 100(2)The further period on sufficient cause 100(3), with rule 106Form, fee and verification
Source
Law text	CBIC tax information portal, served on 17 September 2026^[1]
Questions reviewed	Prashant Prakash, 22 September 2026

Text

The text below is the section as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.^[1] The Act as published in the Gazette of India is the legal source.

Section 100, verbatim (show)

* Section 100. Appeal to Appellate Authority. -

(1) The concerned officer, the jurisdictional officer or an applicant aggrieved by any advance ruling pronounced under sub-section (4) of section 98, may appeal to the Appellate Authority.

(2) Every appeal under this section shall be filed within a period of thirty days from the date on which the ruling sought to be appealed against is communicated to the concerned officer, the jurisdictional officer and the applicant:

Provided that the Appellate Authority may, if it is satisfied that the appellant was prevented by a sufficient cause from presenting the appeal within the said period of thirty days, allow it to be presented within a further period not exceeding thirty days.

(3) Every appeal under this section shall be in such form, accompanied by such fee and verified in such manner as may be prescribed.

*Enforced w.e.f. 1st July, 2017.

Questions to answer on the file

Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.

Scope the section as a whole

Questions to answer on the file1 question

What is the matter, from the things this section speaks about?

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Who may appeal and against what 100(1)

Questions to answer on the file4 questions

Has an advance ruling been pronounced under sub-section (4) of section 98?
Who has presented the appeal: the concerned officer, the jurisdictional officer or an applicant?
Is the person appealing aggrieved by the advance ruling?
Has the appeal been presented to the Appellate Authority?

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The thirty days for filing the appeal 100(2)

Questions to answer on the file4 questions

On what date was the ruling communicated to the concerned officer?
On what date was the ruling communicated to the jurisdictional officer?
On what date was the ruling communicated to the applicant?
On what date was the appeal filed?

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The further period on sufficient cause the proviso to 100(2)

Questions to answer on the file4 questions

Has the appellant put a cause before the Appellate Authority for not presenting the appeal within the thirty days?
Was the Appellate Authority satisfied that the appellant was prevented by a sufficient cause?
Did the Appellate Authority allow the appeal to be presented within the further period?
Is the delay beyond the first thirty days itself not more than thirty days?

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Form, fee and verification 100(3), with rule 106

Questions to answer on the file4 questions

Is the appeal in the form prescribed?
Is the appeal accompanied by the fee prescribed?
Is the appeal verified in the manner prescribed?
Which prescribed form does the appeal take: FORM GST ARA-02, the appeal made by an applicant or FORM GST ARA-03, the appeal made by the concerned officer or the jurisdictional officer?

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Amendment history

The CBIC text carries 1 footnote. The table gives each in the source's own terms. Effective dates are as the footnotes state them.^[1]

Amendments to section 100 as footnoted in the CBIC text
Note	Change	Instrument	Effective from
	brought section 100 into force	none — the source's own enforcement note, not an amendment footnote	1 July 2017

Provisions connected to Section 100
Provision	Connection	Words that tie them
Section 98	Section 98 requires this provision	100(1) "an applicant aggrieved by any advance ruling pronounced under sub-section (4) of section 98, may appeal"
Section 99	this provision requires Section 99	100(1) "may appeal to the Appellate Authority" — section 99 says which body that is
Section 101	this provision requires Section 101	101(2) "within a period of ninety days from the date of filing of the appeal under section 100"
Rule 106 of the CGST Rules, 2017	100(3) prescribed by Rule 106 of the CGST Rules, 2017	100(3) "in such form, accompanied by such fee and verified in such manner as may be prescribed"; rule 106(1) "in FORM GST ARA-02 and shall be accompanied by a fee of ten thousand rupees"
Rule 106 of the CGST Rules, 2017, Section 49	Rule 106 of the CGST Rules, 2017 requires Section 49	rule 106(1) "to be deposited in the manner specified in section 49"
Rule 106 of the CGST Rules, 2017, Rule 26 of the CGST Rules, 2017	Rule 106 of the CGST Rules, 2017 requires Rule 26 of the CGST Rules, 2017	rule 106(3)(b) "in the case of an applicant, in the manner specified in rule 26"
Section 95	this provision defined by Section 95	the words "advance ruling", "Appellate Authority", "applicant" and "concerned officer" are defined for this Chapter in section 95
Rule 107A of the CGST Rules, 2017	this provision prescribed by Rule 107A of the CGST Rules, 2017	rule 107A "any reference to electronic filing of an application... shall... include manual filing"

Circulars and notifications

Circulars and notifications in the CBIC repository that cite this section, newest first, by number, date and subject. A listing here does not say what an instrument decides; read the instrument.

Circulars (1)

Number	Date	Subject
Circular No. 25/25/2017-GST	21 December 2017	Manual filing of applications for Advance Ruling and appeals before Appellate Authority for Advance Ruling.

Notifications (4)

Number	Date	Subject
Notification No. 18/2022-Central Tax	28 September 2022	Seeks to notify 01.10.2022 as the date on which provisions of sections 100 to 114, except clause (c) of section 110 and section 111 of Finance Act, 2022 shall come into force.
Notification No. 63/2020-Central Tax	25 August 2020	Seeks to notify the provisions of section 100 of the Finance (No. 2) Act, 2019 to amend section 50 of the CGST Act, 2017 w.e.f. 01.09.2020.
Notification No. 01/2020-Central Tax	1 January 2020	Seeks to bring into force certain provisions of the Finance (No. 2) Act, 2019 to amend the CGST Act, 2017.
Notification No. 10/2017-Central Tax	28 June 2017	Seeks to amend CGST Rules notification no 3/2017-Central Tax dt 19.06.2017 amended by a later instrument

Unsettled questions

The words of section 100 do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.

Who may appeal under section 100(1)? The sub-section names the concerned officer, the jurisdictional officer and an applicant and then says "aggrieved by any advance ruling", and it nowhere says what makes a person aggrieved, nor whether the word qualifies the two officers as well as the applicant.
From which date do the thirty days run? Sub-section (2) fixes the period from "the date on which the ruling sought to be appealed against is communicated to the concerned officer, the jurisdictional officer and the applicant", names three recipients who may be told on three different dates, and does not say whether the period runs from the appellant's own date, from the earliest of the three or from the latest.

See also

Section 98 of the CGST Act, 2017: procedure on receipt of application
Rule 106 of the CGST Rules, 2017: form and manner of appeal to the Appellate Authority for Advance Ruling

References

Central Board of Indirect Taxes and Customs. "Section 100. Appeal to Appellate Authority". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.

External links

CGST Act, 2017, Section 100 on the CBIC tax information portal