FORM GST ARA-02 - Applicant appeal to Appellate Authority for Advance Ruling
An applicant challenges a communicated advance ruling on specified grounds within the statutory period.
Responsible actor: The applicant aggrieved by an AAR ruling files the appeal. Provision: Section 100; rule 106(1) and (3).
Official source and completed example
Download official blank source extract PDF Download completed fictional sample PDF
The sample is a flowed model of the prescribed fields and selected paragraphs, not an official issued PDF. Names, references and facts are fictional. It contains no signature, stamp, DSC or simulated approval.
Law checked 21 October 2026; blank form structure preserved from official 1 January 2022 Part B. Advance-ruling sections 95–103 and rule 104/106, ICAI April 2026 bare law PDF page 311; hypothetical rulings are expressly fictional.
Worked facts and completed entries
In an expressly fictional continuation, an adverse ruling communicated 15 September 2026 treats the two warehouse addresses as distinct persons despite one GSTIN. Aster appeals 25 September, ten days after communication, supplies its registration schedule and seeks correction. This is a teaching hypothesis, not an allegation about an actual authority.
1–13. Ruling, appellant and jurisdiction
| 1. Advance ruling number | ILLUSTRATION-AAR-2026-01 |
|---|---|
| 2. Date of communication | 15 September 2026 |
| 3. GSTIN | 29AABCA0000A1ZT |
| 4. Legal name | Aster Learning Supplies Private Limited (fictional) |
| 5. Trade name | Aster Learning Shop (fictional) |
| 6. Notice address | 12 Learning Park, Bengaluru, Karnataka 560001 (fictional) |
| 7. Email | aster@example.test |
| 8. Mobile | 0000000000 (fictional non-operational contact) |
| 9. Jurisdictional/concerned officer | N. Prakash (fictional) |
| 10. Officer designation | Assistant Commissioner, Bengaluru (fictional) |
| 11. Officer email | officer@example.test |
| 12. Officer mobile | 0000000000 (fictional non-operational contact) |
| 13. Personal hearing requested? | Yes |
14. Facts
The appealed teaching ruling concerns the proposed same-owner, same-GSTIN movement of 100 modules valued INR 2,00,000 between two declared Bengaluru premises. It assumes distinct-person treatment from different addresses alone. The registration annexure, ownership ledger and no-consideration delivery-challan draft were already part of the applicant’s record.
15. Grounds of appeal
Ground 1: separate premises within one GST registration were treated as separate registered/distinct persons without applying section 25(4)/(5). Ground 2: the recorded facts show no consideration, transfer of ownership or identified Schedule I event on the chosen facts. Ground 3: the registration premises schedule and common-owner stock record were not addressed in the reasoning. The appellant requests examination of those precise documents; it does not contend that every transfer between different registrations is tax-free.
16. Fees and filing
| CIN/reference | ILLUSTRATION-ARA02-FEE-2026-01 — not a real bank receipt |
|---|---|
| Fee date | 25 September 2026 |
| CGST appeal fee under rule 106(1) | INR 10,000 |
| Corresponding KGST appeal fee | INR 10,000 |
| Total assumed appeal fees | INR 20,000 |
| Appeal filing date | 25 September 2026 |
| Elapsed from communication | 10 days; within ordinary 30-day period |
Prayer
The fictional appellant asks the Appellate Authority for Advance Ruling, Karnataka, to set aside or modify the identified adverse finding after considering the one-registration evidence, grant a personal hearing and pass a reasoned order on the stated same-GSTIN facts. No appellate decision is assumed by this completed appeal.
Verification
I, Meera Rao, daughter of Vijay Rao, authorised director of the fictional applicant, declare that the application/appeal and annexures accurately describe the assumed facts and that I am competent to verify this educational model. Place: Bengaluru. Date: 25 September 2026. Signature/DSC: not executed; no real filing or ruling is represented.
How this form moves the matter forward
- Record the actual date of communication, not merely the date printed on the ruling.
- File within thirty days; a further period not exceeding thirty days requires sufficient cause under section 100(2), not an automatic extension.
- Attach the ruling, precise grounds, evidence already on record and applicable fee proof, and track hearing and appellate decision.
Evidence supporting these entries
- Communicated AAR ruling and service evidence
- Original application and same-GSTIN premises/ownership record
- Appeal grounds, fee proof and actual filing acknowledgement
Additional primary authority: CBIC circular 25/25/2017-GST, 21 December 2017, paragraphs 4 and 6: INR 5,000 / 10,000 each under CGST and respective SGST Acts; historical manual-filing instructions apply only while the module was unavailable.
Additional primary authority: State tax department hosted ICAI Handbook on Advance Ruling, December second edition, PDF page 19 / printed page 10: fees payable under each of CGST and respective State Act; refers to CBIC circular 25/25/2017-GST.
Period and legal consequences
ARA-02 is the applicant’s appeal. The concerned/jurisdictional officer uses ARA-03 and pays no fee under rule 106(2). This example’s ordinary deadline would be 15 October 2026, on the assumed 15 September communication.
Primary source and exact locator
Official notified form source: PDF pages 334-335; printed pages 328-329.
CGST Act and government-hosted Act and Rules compilation - Section 100; rule 106(1) and (3). Source and example revision: 21 October 2026.
Questions answered by this example
Who prepares or issues this form?
The applicant aggrieved by an AAR ruling files the appeal. An applicant challenges a communicated advance ruling on specified grounds within the statutory period.
Can this sample be filed or treated as an issued document?
No. It is a completed fictional teaching example. Use the notified form and the authenticated portal/proceeding record for an actual matter. The example contains no executed signature or official approval.
What must reconcile before the next step?
Communicated AAR ruling and service evidence; Original application and same-GSTIN premises/ownership record; Appeal grounds, fee proof and actual filing acknowledgement.