GST ARA-03: appeal by the officer against an advance ruling

When ARA-03 is filed

After the AAR pronounces a ruling, a copy goes to the applicant and to the concerned and jurisdictional officers. If the department disagrees, the officer may file ARA-03 within 30 days of communication of the ruling, with a further 30 days allowed by the AAAR for sufficient cause.

Effect on the applicant

The ruling continues to apply until the AAAR modifies it. However, if the AAAR changes the ruling, the modified position will bind you from then on, so plan pricing, invoicing and ITC decisions with that risk in mind.

The AAAR is to decide the appeal within 90 days of its filing.

Where your supply contracts or customer pricing depend on the ruling, tell the other party that a department appeal is pending, so that contract terms can allow for a possible change in the tax position.

How to respond

• Obtain the full copy of the department's appeal and grounds
• File written submissions supporting the ruling, point by point
• Correct any misstatement of facts in the appeal
• Attend the hearing, which may be held by video conference
• Keep records showing you acted in line with the ruling while the appeal was pending

If the members differ

Where the two members of the AAAR do not agree on a question, no advance ruling is deemed to have been issued on that question. That outcome leaves you without a binding answer, so prepare for it by keeping your own documented legal position. A professional can prepare submissions and represent you before the AAAR.

Get it handled for you

Facing an order you disagree with? We draft and file the appeal with the pre-deposit and attend the hearing as your authorised representative. Call or WhatsApp +91 63677 44602, or use the form below.

This guide explains the law in general terms as of October 2026. Time limits and requirements can depend on the facts of your case and on the notice you received.