Section 101C governs decisions of the National Appellate Authority: it hears all sides, decides by majority, and its ruling binds all registrations under the same PAN.
Key points
- Under section 101C of the CGST Act, 2017 the National Appellate Authority, after hearing the applicant, the authorised officer and the tax administrations of the States concerned, confirms or modifies the rulings appealed against.
- Differences are decided by majority (section 101C(2)); the order is to be passed, as far as possible, within ninety days (section 101C(3)).
- Its ruling binds all registered persons with the same PAN and their officers (section 103(1A)).
The provisions
101C(1)–(4)Order of the National Appellate Authority
Statutory text
(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.
The National Appellate Authority provisions (sections 101A to 101C and the related amendments to sections 95 and 102 to 106) were enacted by the Finance (No. 2) Act, 2019, and the CBIC text still records them as effective "from a date to be notified". No National Appellate Authority has been constituted. Instead, section 101A(1A), inserted by the Finance Act, 2026 from 01.04.2026, lets the Government notify an existing authority, including a Tribunal, to act in its place; by a notification of 07.05.2026, effective 01.04.2026, the Principal Bench of the GST Appellate Tribunal was so designated. Check the current notifications before relying on an appeal under section 101B.
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
- Whom does a National Appellate Authority ruling bind?
- All registered persons with the same PAN as the applicants, and their officers (section 103(1A) CGST).
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
Unlike the State Appellate Authority, it cannot end in a deadlock: the majority view prevails.