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 103, verbatim (show)
*Section 103. Applicability of advance ruling. -
(1) The advance ruling pronounced by the Authority or the Appellate Authority under this Chapter shall be binding only-
(a) on the applicant who had sought it in respect of any matter referred to in sub section (2) of section 97 for advance ruling;
(b) on the concerned officer or the jurisdictional officer in respect of the applicant.
1[(1A) The Advance Ruling pronounced by the National Appellate Authority under this Chapter shall be binding on-
(a) the applicants, being distinct persons, who had sought the ruling under sub-section (1) of section 101B and all registered persons having the same Permanent Account Number issued under the Income-tax Act, 1961 (43 of 1961.);
(b) the concerned officers and the jurisdictional officers in respect of the applicants referred to in clause (a) and the registered persons having the same Permanent Account Number issued under the Income-tax Act, 1961 (43 of 1961).]
(2) The advance ruling referred to in sub-section (1) 2[and sub-section (1A)] shall be binding unless the law, facts or circumstances supporting the original advance ruling have changed. *Enforced w.e.f. 1st July, 2017.
1. Inserted by s.107 of the Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.
2. Inserted by s.107 of the Finance (No. 2) Act, 2019 (23 of 2019). This amendment shall be effective from a date to be notified.
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
On whom the advance ruling is binding 103(1)(a) and (b)
Questions to answer on the file6 questions
Whether the ruling continues to bind 103(2)
Questions to answer on the file2 questions
Whether sub-section (1A) is in force footnotes 1 and 2
Questions to answer on the file1 question
Amendment history
The CBIC text carries 3 footnotes. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]
| Note | Change | Instrument | Effective from |
|---|---|---|---|
| enforced | the Act itself | 01.07.2017 | |
| 1 | inserted | s.107 of the Finance (No. 2) Act, 2019 (23 of 2019)[2] | a date to be notified — not in force |
| 2 | inserted | s.107 of the Finance (No. 2) Act, 2019 (23 of 2019)[2] | a date to be notified — not in force |
Relationship with other provisions
| Provision | Connection | Words that tie them |
|---|---|---|
| Section 97 | this provision requires Section 97 97(2) | 103(1)(a) "in respect of any matter referred to in sub section (2) of section 97 for advance ruling" |
| Section 98, Section 101 | this provision branches on Section 98 and Section 101 | 103(1) "The advance ruling pronounced by the Authority or the Appellate Authority under this Chapter" |
| Section 104 | Section 104 overridden by this provision | 104(1) "declare such ruling to be void ab-initio and thereupon all the provisions of this Act... shall apply... as if such advance ruling had never been made" |
| Section 101B | 103(1A) requires Section 101B 101B(1) | 103(1A)(a), not in force, "who had sought the ruling under sub-section (1) of section 101B" |
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.
Notifications (2)
| Number | Date | Subject |
|---|---|---|
| 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. 39/2019-Central Tax | 31 August 2019 | Seeks to bring Section 103 of the Finance (No. 2) Act, 2019 in to force. |
Unsettled questions
The words of section 103 do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.
- From what date does an advance ruling cease to bind when the law, facts or circumstances supporting it have changed, and who decides that they have changed: sub-section (2) states the condition and names neither a date nor a decider
- What being "binding" requires of the applicant and of the officer, and what follows where either acts contrary to a binding advance ruling: sub-section (1) makes the ruling binding and attaches no consequence to departing from it
See also
- Section 104 of the CGST Act, 2017: advance ruling to be void in certain circumstances
- Section 101B of the CGST Act, 2017: appeal to National Appellate Authority
References
- Central Board of Indirect Taxes and Customs. "Section 103. Applicability of advance ruling". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 3. Retrieved 17 September 2026.
- The Finance (No. 2) Act, 2019. Cited in CBIC footnotes 1 and 2.
External links
- CGST Act, 2017, Section 103 on the CBIC tax information portal