Chapter XVII - Advance ruling
Section 101B
Section 101B: Appeal against conflicting advance rulings
Section 101B provides a national route for conflicting advance rulings of State or UT Appellate Authorities on section 97(2) questions.
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This article is for general information. Refer to the Central Goods and Services Tax Act, 2017 official text for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(1) Where, in respect of the questions referred to in sub-section (2) of section 97, conflicting Advance Rulings are given by the Appellate Authorities of two or more States or Union territories or both under sub-section (1) or sub-section (3) of section 101, any officer authorised by the Commissioner or an applicant, being distinct person referred to in section 25 aggrieved by such Advance Ruling, may prefer an appeal to National Appellate Authority: Provided that the officer shall be from the States in which such Advance Rulings have been given.
(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 applicants, concerned officers and jurisdictional officers: Provided that the officer authorised by the Commissioner may file appeal within a period of ninety days from the date on which the ruling sought to be appealed against is communicated to the concerned officer or the jurisdictional officer: Provided further that the National 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, or as the case may be, ninety days, allow such appeal to be presented within a further period not exceeding thirty days.
Explanation.—For removal of doubts, it is clarified that the period of thirty days or as the case may be, ninety days shall be counted from the date of communication of the last of the conflicting rulings sought to be appealed against.
(3) Every appeal under this section shall be in such form, accompanied by such fee and verified in such manner as may be prescribed.
Key takeaways
Conflict requirement
There must be conflicting Appellate Authority advance rulings from at least two States or Union territories on a permitted question.
Eligible appellant
An aggrieved applicant who is a distinct person under section 25, or a Commissioner-authorised officer from the relevant States, may appeal.
Filing period
The applicant ordinarily has thirty days and the authorised officer ninety days from communication of the last conflicting ruling; sufficient cause can allow up to thirty further days.
Conflict requirement
There must be conflicting Appellate Authority advance rulings from at least two States or Union territories on a permitted question.
Eligible appellant
An aggrieved applicant who is a distinct person under section 25, or a Commissioner-authorised officer from the relevant States, may appeal.
Filing period
The applicant ordinarily has thirty days and the authorised officer ninety days from communication of the last conflicting ruling; sufficient cause can allow up to thirty further days.
Practical checklist
Do
- Collect both conflicting appellate rulings and communication dates.
- Identify distinct-person status or officer authority.
- Verify current Principal Bench filing form, fee and process.
Frequently asked questions
Which ruling starts the appeal clock?
The explanation measures the period from communication of the last conflicting ruling sought to be appealed.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026