Tamil Nadu AAR Holds Advance Ruling Application May Be Withdrawn Upon Applicant’s Request Following Government Clarification on GST Rate

Tamil Nadu Authority for Advance Ruling (AAR) has clarified the procedural aspect regarding the withdrawal of advance ruling applications under the Goods and Services Tax (GST) regime. The ruling was delivered in the matter concerning M/s. Kaleesuwari Refinery Private Limited, a manufacturer and marketer of edible oils, who had sought an advance ruling on the classification and applicable GST rate for their new product, “Dheepam Lite,” made from 100% refined rice bran oil.

The applicant initially approached the AAR seeking clarity on two specific issues: (1) the appropriate HSN code for rice bran oil under GST classification norms, and (2) whether the applicable GST rate for the edible oil was 5% or 12%. The application was duly filed, and the applicant provided detailed information regarding the product’s composition, regulatory compliance, and intended labeling.

However, before the matter could be adjudicated, the applicant submitted a request to withdraw the application. This request was prompted by the issuance of a Central Government clarification through Notification No. 9/2025, Central Tax Rate, dated 17.09.2025, which prescribed the applicable GST rate for the product in question under the GST 2.0 reform. The applicant indicated that, in light of this clarification, there was no longer a need to pursue the advance ruling.

Upon consideration, the AAR recorded the applicant’s withdrawal request and allowed the application to be treated as withdrawn. The Authority expressly stated that the application was disposed of without entering into the merits or detailed facts of the case. The ruling reiterates that, in accordance with the statutory framework, an advance ruling is binding only on the applicant and the jurisdictional officer, and remains so unless there is a change in law, facts, or circumstances. Furthermore, the AAR noted that any advance ruling obtained by fraud, suppression, or misrepresentation is void ab initio.

This decision underscores the procedural flexibility available to applicants before the AAR, allowing them to withdraw applications when subsequent government notifications or clarifications resolve the underlying issues. The ruling also highlights the importance of government notifications in providing clarity and reducing the need for individual advance rulings on matters that have been conclusively addressed by statutory instruments.

In conclusion, the Tamil Nadu AAR disposed of the application as withdrawn, setting out that such withdrawal is permissible upon the applicant’s request when a government clarification renders the advance ruling unnecessary.