Grounds Incomplete and Vague: AAR Dismisses Advance Ruling Request on DM Water, Distil Water & Conductive Water [Read Order]

The Gujarat Authority for Advance Ruling (AAR) has dismissed an application seeking a classification and GST ( Goods and Services Tax ) rate ruling on commodities such as DM Water, Distil Water, and Conductive Water, holding that the request was vague, incomplete, and lacked the requisite details mandated under law.

The application, filed on 24 December 2024, by Royal Enterprises did not provide any information about the applicant’s business activities, the nature of supply undertaken, inputs used, or any other particulars necessary to decide the matter.

The documents annexed included only an undated and unsigned letter along with a certificate of analysis from a laboratory, which the AAR found irrelevant for the purpose of classification. During the personal hearing on 24 April 2025, the authorized representative of the applicant fairly admitted that the application lacked the necessary details and supporting write-up.

The bench of Kamal Shukla and P.B. Meena, stating Section 98(2) of the CGST Act, 2017, which empowers the Authority to reject applications that are incomplete or deficient, the AAR observed that the absence of primary details made it impossible to adjudicate the classification or rate of tax issue raised.

Accordingly, the bench rejected the application in its entirety, ruling that an advance ruling cannot be sought on vague and unsubstantiated grounds.

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