M/s Apoorva Limited, a domestic company intends to start a new business in Mumbai, involving supply of goods which are mostly meant for foreign…

CA Final · Indirect Tax Laws · PYQS · January 2026
M/s Apoorva Limited, a domestic company intends to start a new business in Mumbai, involving supply of goods which are mostly meant for foreign buyers located in Sri Lanka. There are some difficulties being faced by M/s Apoorva Limited in determination of classification and place of supply of goods. M/s Apoorva Limited wants to seek advance ruling from the authority for Advance Ruling in respect of both the above issues. However, M/s Apoorva Limited has the following apprehensions: (i) That it cannot seek advance ruling with respect to determination of place of supply of Goods in the proposed transactions. (ii) The advance ruling cannot be sought unless it is registered under CGST Act, 2017. (iii) If the advance ruling is sought, it has to seek ruling every financial year. (iv) Whether the ruling given by AAR of one state/UT shall be applicable in other States/UTs. (v) Whether appeal lies to AAAR against the orders of AAR and whether the orders by AAAR is final and cannot be further appealed against. As a GST consultant you are required to advise M/s Apoorva Limited with reasons for your advice.

Suggested Answer and Working Notes:

Answer (a) (i) Yes, M/s Apoorva Limited is correct M/s Apoorva Limited cannot seek advance ruling with respect to determination of place of supply. (ii) No, M/s Apoorva Limited is not correct M/s Apoorva Limited can seek advance ruling since a person desirous of obtaining GST registration is also eligible to seek advance ruling 16 . (iii) No, M/s Apoorva Limited is not correct. There is no need to take advance ruling for every financial year. Advance Ruling once sought will be binding till the time the law, facts and circumstances supporting the original advance ruling remain same. (iv) No, the ruling given by the AAR of one State/UT will not be applicable in any other States/UT. (v) Yes, M/s Apoorva Limited is correct since appeal lies to AAAR against the orders of AAR and no further appeal lies beyond the appeal against order of AAAR as same is final. 16 It is important to note here that M/s Apoorva Limited, though not registered, is eligible to seek advance ruling. However, it can seek advance ruling on an issue other than place of supply.

Topics: Advance Ruling

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