Section 103: Binding Only on the Applicant

Section 103 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

The word that governs the whole Chapter is "only". Every practical question about the value of a ruling — yours or somebody else's — starts there.

Section 103(1): the advance ruling pronounced by the Authority or the Appellate Authority shall be binding only — (a) on the applicant who sought it in respect of any matter referred to in s.97(2); and (b) on the concerned officer or the jurisdictional officer in respect of the applicant. 103(1A): a ruling of the National Appellate Authority binds the applicants, being distinct persons, who sought it under s.101B(1) and all registered persons having the same PAN, and the concerned and jurisdictional officers in respect of them. 103(2): the ruling is binding unless the law, facts or circumstances supporting the original advance ruling have changed.

What "only" excludes

Other taxpayers. A ruling obtained by a competitor on an identical product does not bind you, and does not bind your officer.

Your other registrations. A ruling obtained by a company for its Karnataka GSTIN does not bind the officer dealing with its Maharashtra GSTIN — even though it is the same legal entity, because s.103(1)(b) binds the officer in respect of the applicant, and each registration is a distinct person under s.25(4).

Group companies. Separate legal persons, separate applicants.

Your customers and suppliers. The ruling does not bind them, and a customer cannot insist on a rate because your ruling says so — nor can a supplier resist one.

Later periods where the position has changed. Handled by s.103(2).

Section 103(1A): the wider effect, and its condition

The National Appellate Authority route is the only mechanism that produces a ruling binding beyond a single registration.

Section 103(1A) binds:

• the applicants, being distinct persons, who sought the ruling under s.101B(1); and
• all registered persons having the same Permanent Account Number issued under the Income-tax Act, 1961;
• and the concerned and jurisdictional officers in respect of all of them.

So a NAAAR ruling reaches every GSTIN of the same PAN.

But the route is narrow. Section 101B exists to resolve conflicting rulings given by Appellate Authorities of different States or Union territories on the same question, in the case of distinct persons. It is not a general second appeal.

And its availability turns on the empowerment. Section 101A(1A), inserted by the Finance Act, 2026 w.e.f. 01.04.2026, allows the Government, until the National Appellate Authority is constituted under s.101A(1), to empower any existing Authority — including a Tribunal — by notification to hear s.101B appeals, in which case sub-sections (2) to (13) of s.101A do not apply and references to the National Appellate Authority are read as references to that Authority. The empowered Tribunal as NAAAR →

Section 103(2): when a ruling stops binding

"The advance ruling referred to in sub-section (1) and sub-section (1A) shall be binding unless the law, facts or circumstances supporting the original advance ruling have changed."

Three independent triggers, and any one of them ends the binding effect.

Law changed. An amendment to the Act, a new or amended notification, a substituted rule. The GST 2.0 rate reset from 22.09.2025 is the obvious recent example: a ruling on rate or classification decided against the earlier notification structure does not carry forward unexamined. GST 2.0 rate structure →

Facts changed. The product specification, the contract terms, the pricing mechanism, the delivery model.

Circumstances changed. The surrounding commercial arrangement — a new intermediary, a changed supply chain, a different counterparty relationship.

The consequence cuts both ways. A taxpayer relying on a favourable ruling after a change is not protected. A taxpayer bound by an adverse ruling is released once the law, facts or circumstances genuinely change — and that is a real route out of an unhelpful ruling.

What to do: review every ruling relied on whenever the law changes or the transaction changes, and record the review. A ruling in the file that has quietly stopped applying is worse than no ruling, because it produces false comfort.

What another person's ruling is actually worth

Not binding — but not worthless either.

As a reasoned view. A ruling is a decision of a statutory authority with civil court powers under s.105, reached after hearing both sides. Its reasoning can be cited.

As evidence of an arguable position. Where a taxpayer takes a position supported by a ruling on similar facts, that is strong material against a suppression or wilful misstatement characterisation. The suppression allegation →

As a signal of divergence. Conflicting rulings across States on the same question are precisely the material that supports a s.101B reference where the applicants are distinct persons, and they are worth tracking for that reason.

As a warning. An adverse ruling elsewhere on your fact pattern tells you what the department will argue, and lets you prepare the distinguishing features before a notice arrives.

What it is not: a defence. The department is not bound by another taxpayer's ruling, and a reply that rests only on one is thin.

Key takeaways

• Section 103(1): binding only on the applicant and on the officers in respect of the applicant.
• It does not bind other taxpayers, group companies, customers, suppliers, or the applicant's other GSTINs.
• Section 103(1A): a National Appellate Authority ruling binds all registered persons with the same PAN.
• The s.101B route addresses conflicting rulings between States for distinct persons, not general appeals.
• Section 103(2): binding unless the law, facts or circumstances have changed — which cuts both ways.
• Another person's ruling is persuasive, evidence of an arguable position, and a warning — not a defence.

Read next

• Section 104: When an Advance Ruling Becomes Void Ab Initio
• Section 100: Appeal to the AAAR, ARA-02 and ARA-03
• What an Advance Ruling Cannot Decide
• When to Seek an Advance Ruling, and When Not To

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Act as amended to 31 March 2026 (ICAI Bare Law, 12th edition).