Chapter XVII - Advance ruling
Section 101C
Section 101C: Order on conflicting advance rulings
The national appeal authority hears the affected participants and can confirm or modify conflicting advance rulings.
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Need advice on Section 101C?
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) 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.
Key takeaways
Hearing
The Act requires an opportunity of hearing for the applicant, authorised officer and specified central, State and UT commissioners.
Decision
The authority can confirm or modify the appealed rulings; a member difference is resolved by majority where the original body rules apply.
Timeliness and communication
The order should, as far as possible, issue within ninety days of appeal filing and is circulated as specified.
Hearing
The Act requires an opportunity of hearing for the applicant, authorised officer and specified central, State and UT commissioners.
Decision
The authority can confirm or modify the appealed rulings; a member difference is resolved by majority where the original body rules apply.
Timeliness and communication
The order should, as far as possible, issue within ninety days of appeal filing and is circulated as specified.
Practical checklist
Do
- Prepare both conflicting rulings and supply facts.
- Track the section 101B appeal filing date.
- Check the decision’s binding effect under section 103.
Frequently asked questions
Can a national appeal order modify a conflicting State ruling?
Yes. Section 101C(1) authorises confirmation or modification after hearing.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026