Section 102 lets the Authority correct obvious mistakes in its own ruling within six months — but not to its disadvantage without hearing the applicant.
Key points
- Under section 102 of the CGST Act, 2017 the Authority or Appellate Authority may amend its order to rectify an error apparent on the face of the record, noticed on its own or brought to its notice by the applicant or the officers, within six months of the order.
- A rectification that increases tax or reduces admissible credit requires a prior hearing (proviso).
The provisions
102Rectification of advance ruling
Statutory text
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.
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
- Can an advance ruling be corrected?
- Yes, for an error apparent on the face of the record, within six months of the order (section 102 CGST), with a hearing if the change is adverse.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
Rectification is for errors apparent on the record — a clerical slip, an overlooked notification — not for re-argument of the ruling.