Section 103 of the CGST Act, 2017

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

At a glance

Entitlement and conditions

  • 103(1)–(2)The Authority’s or Appellate Authority’s ruling binds the applicant and relevant officer for that applicant unless the supporting law, facts or circumstances change. Section 104 provides for invalidation.

Procedure, powers and definitions

  • 103(1A) pendingThe pending national-ruling rule would bind distinct-person applicants, all registered persons sharing their Permanent Account Number and the relevant officers, with the same change-of-circumstances qualification.
  • 103The law does not settle when changed circumstances end binding effect, who decides that question, what binding requires in practice or the consequence of departure.

An advance ruling binds only its applicant and the concerned or jurisdictional officer in relation to that applicant. Its binding effect depends on the supporting law, facts and circumstances remaining unchanged, and section 104 can invalidate a ruling obtained improperly. The proposed extension to national rulings and registered persons sharing a Permanent Account Number remains pending notification.[1]

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.

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.

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
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On whom the advance ruling is binding 103(1)(a) and (b)

Questions to answer on the file6 questions
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Whether the ruling continues to bind 103(2)

Questions to answer on the file2 questions
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Whether sub-section (1A) is in force footnotes 1 and 2

Questions to answer on the file1 question
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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]

Amendments to section 103 as footnoted in the CBIC text
NoteChangeInstrumentEffective from
enforcedthe Act itself01.07.2017
1inserteds.107 of the Finance (No. 2) Act, 2019 (23 of 2019)[2]a date to be notified — not in force
2inserteds.107 of the Finance (No. 2) Act, 2019 (23 of 2019)[2]a date to be notified — not in force
Provisions connected to Section 103
ProvisionConnectionWords that tie them
Section 97this 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 101this provision branches on Section 98 and Section 101103(1) "The advance ruling pronounced by the Authority or the Appellate Authority under this Chapter"
Section 104Section 104 overridden by this provision104(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 101B103(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)

NumberDateSubject
Notification No. 01/2020-Central Tax1 January 2020Seeks to bring into force certain provisions of the Finance (No. 2) Act, 2019 to amend the CGST Act, 2017.
Notification No. 39/2019-Central Tax31 August 2019Seeks 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.

  1. 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
  2. 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

References

  1. 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.
  2. The Finance (No. 2) Act, 2019. Cited in CBIC footnotes 1 and 2.

External links