Advance-ruling jurisdiction excludes completed transactions and cannot affirm tax positions already implemented in statutory returns.
Case-Laws
GST
Advance-ruling jurisdiction is confined to supplies being undertaken or proposed and cannot validate a tax position already adopted for completed transactions. Where pre-GST contractual work had ended, arbitral-award amounts were received, and the taxpayer filed GSTR-3B treating them as non-taxable compensation, the application sought confirmation after the event rather than advance certainty. Questions on whether individual award components constitute consideration require examination of contracts, arbitral materials, accounts, returns and evidence by the proper officer through scrutiny or adjudication. Admission by the original authority does not prevent the appellate authority from examining maintainability. The advance ruling was set aside, without any opinion on taxability of the award amounts.
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