Section 102 of CGST Act - Rectification of Advance Ruling
Section 102 of the Central Goods and Services Tax Act, 2017 provides a limited mechanism for correcting an error apparent on the face of the record in an order passed by the Authority for Advance Ruling or the Appellate Authority for Advance Ruling.
Updated: 15 September 2026
- Rectification applies to orders passed under Section 98 or Section 101.
- The error must be apparent on the face of the record.
- The error may be noticed by the Authority or Appellate Authority itself, or brought to its notice by specified persons.
- The statutory period mentioned in Section 102 is six months from the date of the order.
- A hearing is required before a rectification that enhances tax liability or reduces admissible input tax credit.
Text and scope of Section 102
The Authority or the Appellate Authority may amend an order passed by it under Section 98 or Section 101 to rectify an error apparent on the face of the record. The provision operates where the error is noticed on the Authority's own accord or is brought to its notice by the concerned officer, jurisdictional officer, applicant or appellant within six months from the date of the order.
If the proposed rectification would enhance the tax liability or reduce the amount of admissible input tax credit, the applicant or appellant must first be given an opportunity of being heard.
What is rectification under Section 102?
Rectification under Section 102 is a statutory power to correct an identifiable error in an advance ruling order. The provision uses the expression "error apparent on the face of the record". Accordingly, Section 102 is directed at correction of an apparent error in the order and is not framed as a general rehearing or a fresh appeal against the ruling.
Which orders can be rectified?
Section 102 expressly refers to an order passed under Section 98 or Section 101. Section 98 governs the procedure before the Authority for Advance Ruling, while Section 101 deals with orders of the Appellate Authority for Advance Ruling.
Who can bring an error to the Authority's notice?
The provision identifies the concerned officer, the jurisdictional officer, the applicant and the appellant. The Authority or Appellate Authority may also notice the apparent error on its own accord.
Six-month period under Section 102
Section 102 states that the error must be noticed by the Authority or Appellate Authority on its own accord, or brought to its notice by the specified person, within a period of six months from the date of the order. A person seeking rectification should therefore identify the date of the relevant order and act within the statutory period.
Opportunity of hearing
The proviso protects the applicant or appellant where rectification would operate adversely. No rectification having the effect of enhancing tax liability or reducing admissible input tax credit may be made unless an opportunity of being heard has been given.
A rectification request should identify the specific apparent error and the relevant part of the existing record. Where the grievance requires reconsideration of the merits rather than correction of an apparent error, the appropriate statutory remedy, if available, should be examined separately.
Related provisions in Chapter XVII - Advance Ruling
Section 102 forms part of Chapter XVII of the CGST Act. For context, Section 95 contains the relevant definitions, Section 97 governs applications for advance ruling, Section 98 provides the procedure on receipt of an application, Section 100 provides for appeal to the Appellate Authority, and Section 101 governs its orders.
Official GST references
For the statutory text, amendments, notifications and portal procedures, readers should verify the current position from the official sources linked in the sidebar. The CBIC GST portal publishes the CGST Act and advance-ruling material, while the GST common portal provides taxpayer-facing GST services.
Frequently asked questions
Can the Authority rectify an advance ruling on its own?
Yes. Section 102 expressly permits the Authority or Appellate Authority to act on an error apparent on the face of the record noticed on its own accord, subject to the statutory requirements.
What is the time limit stated in Section 102?
The section specifies a period of six months from the date of the order for the apparent error to be noticed or brought to the Authority's notice in the manner stated in the provision.
Is a hearing compulsory in every rectification?
The express proviso requires an opportunity of hearing where the rectification would enhance tax liability or reduce the amount of admissible input tax credit.