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Section 101C of the CGST Act, 2017

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

At a glance

Bars, duties and time limits

101C(4)The pending copy requirement covers the applicant, authorised officer, Board, State and Union territory Chief Commissioners and Commissioners, and the Authority or Appellate Authority; members must sign and certify as prescribed.

Procedure, powers and definitions

101C(1)The pending power permits confirmation or modification after hearing the applicant, authorised officer, all central Principal Chief Commissioners and Chief Commissioners, and State and Union territory Chief Commissioners and Commissioners.
101C(2)–(3)Under the pending text, majority opinion determines disagreement; pass the order as far as possible within ninety days of appeal filing.
101CThe law does not settle the consequence of a late order or what must justify delay.

The proposed national appellate order procedure remains pending notification under the inserting Finance amendment. It would require hearings for the applicant, authorised officer and specified central, State and Union territory tax officials. Members would decide disagreements by majority, with orders targeted within ninety days as far as possible. Signed, certified copies would go to the listed recipients.^[1]

Quick facts

Section 101C, CGST Act, 2017

Order of National Appellate Authority

Provision
Act	Central Goods and Services Tax Act, 2017
Chapter	XVII, Advance Ruling
Section title	Order of National Appellate Authority
Amendments
Amendments	1 footnote in the CBIC text (table)
Pending	Footnote 1: the whole section, heading and sub-sections (1) to (4), not yet notified
Related provisions
Sections	101A, 101B, 102, 104
Structure footnote 1Whether section 101C is in force 101C(1)The order and the opportunity of being heard 101C(2)Difference of opinion among the Members 101C(3)The ninety-day period 101C(4)The copy of the Advance Ruling
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 101C, verbatim (show)

¹[Section 101C. Order of National Appellate Authority.

(1) The National Appellate Authority may, after giving an opportunity of being heard to the applicant, the officer authorised by the Commissioner, all Principal Chief Commissioners, Chief Commissioners of Central tax and Chief Commissioner and Commissioner of State tax of all States and Chief Commissioner and Commissioner of Union territory tax of all Union territories, pass such order as it thinks fit, confirming or modifying the rulings appealed against.

(2) If the members of the National Appellate Authority differ in opinion on any point, it shall be decided according to the opinion of the majority.

(3) The order referred to in sub-section (1) shall be passed as far as possible within a period of ninety days from the date of filing of the appeal under section 101B.

(4) A copy of the Advance Ruling pronounced by the National Appellate Authority shall be duly signed by the Members and certified in such manner as may be prescribed and shall be sent to the applicant, the officer authorised by the Commissioner, the Board, the Chief Commissioner and Commissioner of State tax of all States and Chief Commissioner and Commissioner of Union territory tax of all Union territories and to the Authority or Appellate Authority, as the case may be, after such pronouncement.]

1. Inserted by s. 105 of the Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.

Not yet in force. Footnote 1 records a change with effect from a date yet to be notified: the whole section, heading and sub-sections (1) to (4). This page follows the text as the CBIC portal serves it.

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

Which part of section 101C does the matter turn on?

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Whether section 101C is in force footnote 1

Questions to answer on the file3 questions

Does the matter require section 101C to have been in force?
Has a date been appointed by notification for section 105 of the Finance (No. 2) Act, 2019 (23 of 2019) to come into force?
If so: was the order made on or after the date so appointed?

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The order and the opportunity of being heard 101C(1)

Questions to answer on the file3 questions

Was the applicant given an opportunity of being heard before the order was passed?
Which of the officers named in sub-section (1) was not given an opportunity of being heard?
What does the order do to the rulings appealed against: confirming the rulings appealed against, modifying the rulings appealed against or neither confirming nor modifying them?

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Difference of opinion among the Members 101C(2)

Questions to answer on the file2 questions

Did the members of the National Appellate Authority differ in opinion on any point?
Was that point decided according to the opinion of the majority?

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The ninety-day period 101C(3)

Questions to answer on the file3 questions

What is the date of filing of the appeal under section 101B?
What is the date on which the order under sub-section (1) was passed?
Is the reason the order could not be passed within ninety days on the record?

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The copy of the Advance Ruling 101C(4)

Questions to answer on the file3 questions

Is the copy duly signed by the Members?
Is the copy certified in the manner prescribed?
To which of the persons named in sub-section (4) was the copy not sent?

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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 101c as footnoted in the CBIC text
Note	Change	Instrument	Effective from
1	the whole section, heading and sub-sections (1) to (4)	s. 105 of the Finance (No. 2) Act, 2019 (23 of 2019)^[2]	a date to be notified — not in force

Provisions connected to Section 101C
Provision	Connection	Words that tie them
Section 101B	this provision requires Section 101B	101C(3) "within a period of ninety days from the date of filing of the appeal under section 101B"
Section 101A	this provision defined by Section 101A	101C(1) and (2) speak of "The National Appellate Authority" and of "the members of the National Appellate Authority", which section 101A constitutes
Section 102	Section 102 requires this provision	section 102, in words not in force, would allow an order "under section 101C" to be amended to rectify an error apparent on the face of the record
Section 104	Section 104 requires this provision	section 104, in words not in force, would allow a ruling pronounced "under section 101C" to be declared void ab-initio

Circulars and notifications

No circular or notification in the CBIC repository is recorded as citing this section.

Unsettled questions

The words of section 101c do not answer this question. Where one decides a matter on the file, the answer depends on the position taken on it.

What follows where the order is not passed within ninety days: sub-section (3) says the order "shall be passed as far as possible" within that period, and names neither a consequence for passing it later nor anything that must be shown for the delay

See also

Section 101A of the CGST Act, 2017: constitution of National Appellate Authority for Advance Ruling
Section 101B of the CGST Act, 2017: appeal to National Appellate Authority

References

Central Board of Indirect Taxes and Customs. "Section 101C. Order of National Appellate Authority". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.
The Finance (No. 2) Act, 2019. Cited in CBIC footnote 1.

External links

CGST Act, 2017, Section 101C on the CBIC tax information portal