Section 97 lists the only questions an advance ruling can answer. Anything outside the list — for instance, place of supply — cannot be the subject of a ruling.
Key points
- Under section 97(1) of the CGST Act, 2017 an applicant applies in Form GST ARA-01 with the prescribed fee (Rule 104).
- Under section 97(2) a ruling may be sought only on: classification; applicability of a notification; time and value of supply; admissibility of input tax credit; liability to pay tax; whether registration is required; and whether a particular thing done amounts to a supply.
- Place of supply is not on the list, so Authorities have declined to rule on it.
The provisions
97(1)–(2)Application and permitted questions
Statutory text
(1) An applicant desirous of obtaining an advance ruling under this Chapter may make an application in such form and manner and accompanied by such fee as may be prescribed, stating the question on which the advance ruling is sought.
(2) The question on which the advance ruling is sought under this Act, shall be in respect of,-
(a) classification of any goods or services or both;
(b) applicability of a notification issued under the provisions of this Act;
(c) determination of time and value of supply of goods or services or both;
(d) admissibility of input tax credit of tax paid or deemed to have been paid;
(e) determination of the liability to pay tax on any goods or services or both;
(f) whether applicant is required to be registered;
(g) whether any particular thing done by the applicant with respect to any goods or services or both amounts to or results in a supply of goods or services or both, within the meaning of that term.
*Enforced w.e.f. 1st July, 2017.
- Rule 104, CGST Rules; Form GST ARA-01
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 sought on place of supply?
- No. Place of supply is not among the questions listed in section 97(2) of the CGST Act.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
The fee is Rs. 5,000 under each of the CGST and SGST Acts. The question must relate to the applicant's own supply; a recipient may seek a ruling on its own input tax credit or liability under reverse charge. Whether a recipient may ask how its supplier's supply is taxed is not uniform: Authorities have often refused, but the Calcutta High Court in Anmol Industries v West Bengal Authority for Advance Ruling (21.04.2023) held that a registered recipient is an "applicant" and required its application on an exemption for its procurement to be decided on merits.