GST – National Appellate Authority for Advance Ruling ( 2025 Guide)

The Finance (No. 2) Act, 2019 introduced three new sections—Sections 101A, 101B, and 101C—into the Central Goods and Services Tax Act, 2017, to establish the National Appellate Authority for Advance Ruling (NAAAR). These provisions aim to resolve conflicting Advance Rulings issued by Appellate Authorities of different States or Union Territories.

Recent reforms under the 56th GST Council Meeting (September 2025) have revived and operationalized these provisions through the Goods and Services Tax Appellate Tribunal (GSTAT) framework, setting the stage for a unified appellate mechanism.​

Constitution of the National Appellate Authority for Advance Ruling

Following table summarizes the constitution of the National Appellate Authority along with the eligible criteria thereof:

Appointment of the National Appellate Authority

As seen above, the constitution of the National Appellate Authority consists of the President, The Technical Member (Centre) and The Technical Member (State). Following table helps to understand the appointment of the said members:

 Period of holding of the appointed members of the National Appellate Authority

Advance Ruling under GST

The concept of Advance Ruling under GST serves as a preventive legal mechanism that allows taxpayers to obtain clarity on tax implications before undertaking a transaction. Governed by Sections 95 to 106 of the CGST Act, 2017, it provides written decisions on aspects such as the classification of goods or services, tax liability, input tax credit eligibility, and time or value of supply.

Applications can be made online in Form GST ARA-01 on the GST portal with prescribed fees. The ruling issued by the Authority for Advance Ruling (AAR) is binding on the applicant and the jurisdictional tax officer, ensuring certainty and fewer compliance disputes. Any person aggrieved by the AAR’s decision can appeal to the Appellate Authority for Advance Ruling (AAAR), and in case of conflicting State rulings, the matter may be escalated to the National Appellate Authority functioning under the GST Appellate Tribunal framework from 2025 onward.  

 Click here to know more about the Advance Ruling for Registered Taxpayers  

Appeal to the National Appellate Authority

Under Section 101B, an appeal can be filed by:

• Any officer authorized by the Commissioner, or
• Any applicant (distinct person) aggrieved by conflicting rulings issued by two or more State Appellate Authorities.

The appeal filing time limits are:

• Applicant: within 30 days from communication of ruling.
• Officer authorized by the Commissioner: within 90 days from communication of ruling.​

As per the 2025 framework, appeals will now be filed through the GSTAT online system, ensuring unified registration and tracking across all State benches.​

Order of the National Appellate Authority

As stated in Section 101C, before passing an order:

• All affected parties—including the applicant, authorized officer, all Chief Commissioners of Central and State Tax—must be heard.
• Decisions are made by majority vote among Authority members.
• Orders must be issued within 90 days from the date of filing of appeal.​

From April 2026 onward, such orders will be passed by the Principal Bench of the GST Appellate Tribunal (GSTAT), which now functions as the National Appellate Authority for Advance Ruling.​

Integration under GSTAT (2025 Reform)

The 56th GST Council Meeting (September 3, 2025) decided that there will no longer be a separate National Appellate Authority. Instead:

• The Principal Bench of GSTAT acts as the National Appellate Authority for Advance Ruling.
• It will hear appeals involving conflicting AAR rulings across States/UTs.
• Hearings are scheduled to begin by December 2025, with full operationalization by April 2026.​
• Total of 31 State Benches will be set up across 45 locations, ensuring wider taxpayer access.
• Virtual hearings and electronic case management are included as part of the GST 2.0 digital transformation.​

Miscellaneous Provisions

• Vacancy: In case of the President’s vacancy due to death, resignation, or other reason, the senior-most member acts as interim President until a new appointment.​
• Resignation: Members may resign by giving notice to the government and must continue in office up to three months or until a successor is appointed, whichever is earlier.​
• Digital Integration: With the GSTAT network, rulings and appeals are now tied directly to FORM GST APL-02A and APL-04A, notified under the CGST (Third Amendment) Rules, 2025.​

2025 Highlights – Institutional and Legal Updates

1. Operational Framework: GSTAT principal bench to function as the NAAAR; no separate authority to be created.​
2. Technology Integration: Online GSTAT appeal filing and virtual hearings enabled nationally.​
3. Time-bound Disposal: 90-day disposal limit retained; decisions binding unless stayed by higher judicial authority.​
4. Sectional Clarifications: Sections 101A to 101C now read harmonized with section 109 (GST Appellate Tribunal constitution).​
5. Implementation Date: Functional transition effective November 1, 2025, with hearings commencing December 2025.​

Conclusion

The 2025 reforms represent the first operationalization of the National Appellate Authority framework introduced in 2019. The Authority, now operating through the Principal Bench of GSTAT, provides a nationally uniform platform for resolving conflicting Advance Rulings, strengthening trust and predictability under the GST 2.0 regime.

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