AAR Maharashtra allowed Advance Ruling Withdrawal After Clarity on Export of Services Issue

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 The application was disposed of as withdrawn under Section 98 of the CGST Act and the MGST Act, with no ruling rendered on whether the services constituted export of services or were covered by the cited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.