Section 100 lets either side appeal an advance ruling to the Appellate Authority within thirty days.
Key points
- Under section 100(1) of the CGST Act, 2017 the applicant, the concerned officer or the jurisdictional officer aggrieved by an advance ruling may appeal to the Appellate Authority.
- The appeal must be filed within thirty days of communication, extendable by up to thirty days for sufficient cause (section 100(2)), in Form GST ARA-02 (applicant) or ARA-03 (officer) with the prescribed fee.
The provisions
100(1)–(3)Appeal to the Appellate Authority
Statutory text
(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.
- Rules 106–107, CGST Rules; Forms GST ARA-02, ARA-03
Statutory text as published on the CBIC tax information portal, as on 03.10.2026; the numbered notes record each amendment. Official source
Common questions
- What is the time limit to appeal an advance ruling?
- Thirty days from communication of the ruling, extendable by thirty days for sufficient cause (section 100(2) CGST).
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
There is no further statutory appeal from the Appellate Authority; its order may be challenged by writ petition, as with rulings of the income-tax Authority for Advance Rulings (Columbia Sportswear, Supreme Court, 2012 — see section 103).