Section 99 of CGST Act: Appellate Authority for Advance Ruling

Section 99 of the Central Goods and Services Tax Act, 2017 identifies the Appellate Authority for Advance Ruling for each State or Union territory. It forms part of Chapter XVII, which contains the statutory framework for GST advance rulings.

Updated: 15 September 2026

Section 99 - Appellate Authority for Advance Ruling

Subject to the provisions of this Chapter, for the purposes of this Act, the Appellate Authority for Advance Ruling constituted under the provisions of a State Goods and Services Tax Act or a Union Territory Goods and Services Tax Act shall be deemed to be the Appellate Authority in respect of that State or Union territory.

The provision therefore uses the State or Union territory level Appellate Authority for Advance Ruling as the corresponding appellate authority for purposes of the CGST Act in that jurisdiction.

Meaning and scope of Section 99

Section 95(b) defines the expression "Appellate Authority" for Chapter XVII as the Appellate Authority for Advance Ruling referred to in Section 99. Section 99 then establishes the statutory link between the CGST Act and the Appellate Authority constituted under the relevant State GST Act or Union Territory GST Act.

This arrangement supports a common advance-ruling structure for Central and State or Union territory GST issues instead of requiring a separate CGST appellate advance-ruling body for every jurisdiction.

Role of the Appellate Authority for Advance Ruling

Section 99 principally identifies the authority. The substantive right and procedure for an appeal are dealt with by the succeeding provisions. In particular, Section 100 deals with appeals to the Appellate Authority, while Section 101 deals with orders of the Appellate Authority.

Under the CGST Rules, an applicant's appeal against an advance ruling is made in the prescribed advance-ruling appeal form and the official GST framework prescribes the filing procedure and fee. Readers should verify the current form, procedure and portal functionality from official GST sources before filing.

Important: An Appellate Authority for Advance Ruling under Chapter XVII is different from the general Appellate Authority dealing with appeals against adjudication orders under Section 107. The applicable forum and procedure depend on the nature of the order being challenged.

Practical significance

For a taxpayer or other eligible applicant who has obtained an advance ruling, Section 99 identifies the appellate institution within the State or Union territory framework. The next step is to read Section 100 together with the applicable CGST Rules to determine who may appeal, the time limit, prescribed form, fee and filing requirements.

Advance rulings are applicant-specific. The binding effect of an advance ruling is governed by Section 103 of the CGST Act, subject to the statutory conditions contained in Chapter XVII.