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Section 102 of the CGST Act, 2017

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

At a glance

Entitlement and conditions

102 provisoGive the applicant or appellant a hearing before a correction increases tax liability or reduces admissible input tax credit.

Procedure, powers and definitions

102Correct an apparent error in an order under section 98 or section 101, noticed by the deciding body or brought by the concerned officer, jurisdictional officer, applicant or appellant within six months of the order.
102 footnotesThe national appellate references and expanded list of persons bringing errors remain pending; the operative list still ends with the applicant or appellant.
102The law does not settle whether six months limits only noticing the error or also making the correction.

The Authority or Appellate Authority can correct an apparent error in its ruling, noticed itself or brought to its attention by the specified officer, applicant or appellant within six months. Any correction increasing tax or reducing admissible credit requires a hearing. The Finance amendment extending this machinery to the National Appellate Authority remains pending notification.^[1]

Quick facts

Section 102, CGST Act, 2017

Rectification of advance ruling

Provision
Act	Central Goods and Services Tax Act, 2017
Chapter	XVII, Advance Ruling
Section title	Rectification of advance ruling
Amendments
Last amendment	1 July 2017: enforced (the Act itself)
Amendments	4 footnotes in the CBIC text (table)
Pending	Footnote 1: inserted; Footnote 2: inserted; Footnote 3: substituted for "or the appellant", not yet notified
Related provisions
Sections	98, 101, 101C, 103
Structure the opening wordsThe body and the order it may amend footnotes 1, 2 and 3Whether the National Appellate Authority words are in force the words "so as to rectify any error apparent on the face of the record"The error apparent on the face of the record the words "if such error is noticed ... or is brought to its notice"How the error came to notice the words "within a period of six months from the date of the order"The six months from the date of the order the provisoThe proviso: a hearing before an adverse rectification
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 102, verbatim (show)

* Section 102. Rectification of advance ruling. - The Authority or the Appellate Authority ¹[or the National Appellate Authority] may amend any order passed by it under section 98 or section 101 ²[or section 101C, respectively,], so as to rectify any error apparent on the face of the record, if such error is noticed by the Authority or the Appellate Authority ¹[or the National Appellate Authority] on its own accord, or is brought to its notice by the concerned officer, the jurisdictional officer, the applicant ³[appellant, the Authority or the Appellate Authority] within a period of six months from the date of the order:

Provided that no rectification which has the effect of enhancing the tax liability or reducing the amount of admissible input tax credit shall be made unless the applicant or the appellant has been given an opportunity of being heard. *Enforced w.e.f 1st July, 2017.

1. Inserted by s.106 of Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.

2. Inserted by s.106 of Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.

3. Substituted by s.106 of the Finance (No. 2) Act, 2019 (23 of 2019) for "or the appellant". 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: inserted. This page follows the text as the CBIC portal serves it.

Not yet in force. Footnote 2 records a change with effect from a date yet to be notified: inserted. This page follows the text as the CBIC portal serves it.

Not yet in force. Footnote 3 records a change with effect from a date yet to be notified: substituted for "or the appellant". 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 102 does the matter turn on?

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The body and the order it may amend the opening words

Questions to answer on the file3 questions

Which body passed the order sought to be amended: the Authority or the Appellate Authority?
Under which provision was that order passed: section 98 or section 101?
Is the body proposing to amend the order the same body that passed it?

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Whether the National Appellate Authority words are in force footnotes 1, 2 and 3

Questions to answer on the file2 questions

Is the order sought to be amended one passed by the National Appellate Authority under section 101C?
Has a date been appointed by notification for section 106 of the Finance (No. 2) Act, 2019 (23 of 2019) to come into force?

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The error apparent on the face of the record the words "so as to rectify any error apparent on the face of the record"

Questions to answer on the file3 questions

Is a defect in the order relied on as the reason for amending it?
Does the record of the order itself show the defect, without evidence from outside it?
Is the defect an error apparent on the face of the record?

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How the error came to notice the words "if such error is noticed ... or is brought to its notice"

Questions to answer on the file1 question

By whom was the error noticed or brought to notice: by the Authority or the Appellate Authority on its own accord, by the concerned officer, by the jurisdictional officer, by the applicant or by the appellant?

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The six months from the date of the order the words "within a period of six months from the date of the order"

Questions to answer on the file4 questions

What is the date of the order sought to be amended?
What is the date on which the error was noticed or brought to notice?
What is the date on which the order was amended?
Does the six-month period bind the making of the amendment as well as the noticing of the error?

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The proviso: a hearing before an adverse rectification the proviso

Questions to answer on the file4 questions

Does the rectification touch the tax liability or the admissible input tax credit?
What effect does the rectification have: enhancing the tax liability, reducing the amount of admissible input tax credit or neither of these?
Whose opportunity of being heard does the proviso require here: the applicant or the appellant?
Has that person been given an opportunity of being heard?

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Amendment history

The CBIC text carries 4 footnotes. The table gives each in the source's own terms. Effective dates are as the footnotes state them.^[1]

Amendments to section 102 as footnoted in the CBIC text
Note	Change	Instrument	Effective from
	enforced	the Act itself	01.07.2017
1	inserted	s.106 of the Finance (No. 2) Act, 2019 (23 of 2019)^[2]	a date to be notified — not in force
2	inserted	s.106 of the Finance (No. 2) Act, 2019 (23 of 2019)^[2]	a date to be notified — not in force
3	substituted for "or the appellant"	s.106 of the Finance (No. 2) Act, 2019 (23 of 2019)^[2]	a date to be notified — not in force

Provisions connected to Section 102
Provision	Connection	Words that tie them
Section 98	this provision requires Section 98	"may amend any order passed by it under section 98"
Section 101	this provision requires Section 101	"may amend any order passed by it under section 98 or section 101"
Section 101C	this provision requires Section 101C	footnote 2's "2[or section 101C, respectively,]", which is not in force
Section 103	Section 103 branches on this provision	an order amended under section 102 is the order whose binding effect section 103 speaks of

Circulars and notifications

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

Unsettled questions

The words of section 102 do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.

What makes a defect an error apparent on the face of the record: the section allows an amendment only to rectify such an error and nowhere says what distinguishes it from an error that needs argument to establish
Whether the six months from the date of the order limits only the noticing of the error, which is where the words sit, or also the making of the amendment, which the section leaves undated

See also

Section 98 of the CGST Act, 2017: procedure on receipt of application
Section 101 of the CGST Act, 2017: orders of Appellate Authority

References

Central Board of Indirect Taxes and Customs. "Section 102. Rectification of advance ruling". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 4. Retrieved 17 September 2026.
The Finance (No. 2) Act, 2019. Cited in CBIC footnotes 1, 2 and 3.

External links

CGST Act, 2017, Section 102 on the CBIC tax information portal