In re Roop Rasayan Industries Pvt. Ltd. (GST AAR Maharashtra)
An application for advance ruling was filed before the Authority for Advance Ruling, Maharashtra under Section 97 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017. The applicant sought clarity on the tax treatment of certain services described in the application. Specifically, the questions raised were whether the supply of services qualified as an “export of services” under Section 2(6) of the Integrated Goods and Services Tax Act, 2017, and, if not, whether the supply would fall under entry 12AA of Notification No. 09/2017–Integrated Tax (Rate), as amended by Notification No. 20/2019–Integrated Tax (Rate) dated 30 September 2019.
Before the Authority could examine the factual matrix or interpret the statutory provisions involved, the applicant submitted a written request dated 06 November 2025 stating that clarity on the issues had been obtained from a High Court judgment. On this basis, the applicant expressed that it no longer wished to pursue the advance ruling and requested withdrawal of the application filed on 27 May 2022. The Authority noted that the withdrawal request was voluntary and unconditional. Accordingly, without entering into the merits of the questions raised or recording any findings on the taxability or classification of the services, the Authority allowed the withdrawal. The application was disposed of as withdrawn under Section 98 of the CGST Act and the MGST Act, with no ruling rendered on whether the services constituted export of services or were covered by the cited exemption entry.
FULL TEXT OF THE ORDER OF AUTHORITY FOR ADVANCE RULING,MAHARASHTRA
(Under Section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017)
The present application has been filed under section 97 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017 [hereinafter referred to as “the CGST Act and MGST Act” respectively] M/s. ROOP RASAYAN INDUSTRIES PVT. LTD., the applicant is seeking an advance ruling in respect of the following question.
1. Whether the Supply of Services as specified in the facts of the case is termed as ‘Export of Services’ as per Section 2(6) of IGST Act, 2017?
2. If not covered in (1) above, whether the same falls under the provisions of entry 12AA in Notification No.09/2017 – Integrated Tax (Rate) as notified by the Notification No.20/2019 – Integrated Tax (Rate) dt. 30/09/2019?
The applicant submitted letter dated 06.11.2025 stating that they get clarity form High Court Judgment and they do not wish to seek a ruling on the questions and would like to withdraw the same. Hence, they requested to allow them to withdraw the subject application filed on 27.05.2022.
The request of the applicant to withdraw their application voluntarily and unconditionally is hereby allowed, without going into the merits or detailed facts of the case.
ORDER
(Under section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017)
NO.GST-ARA- 23/2022-23/B- 620
Mumbai, dt. 18/11/2025
The Application in GST ARA Form No. 01 M/s ROOP RASAYAN INDUSTRIES PVT. LTD., vide reference Online ARA Application Dated 27.05.2022 is disposed of, as being awn voluntarily and unconditionally.
