AAR Tamil Nadu Clarifies Ineligibility of Rule 54(1A) Procedure Post Amendment to CGST Act
The present appeal (Form GST ARA-01), dated 14.11.2024, has been filed by a company named MRF Limited before the Authority for Advance Ruling, Tamil Nadu No. 207, 2nd Floor, Papjm Building, No. 1, Greams Road, Chennai 600 006. The appellant is registered under the GST department and has a GSTIN no. 33AAACM4154G1ZU. The company is located at Arakonam-Tiruttani road, Ichiputhur, Arakonam, Tamil Nadu-631 003.
MRF Limited is involved in the manufacturing of automobile Tyres and Tubes and allied products in the State of Tamil Nadu. The applicant not only has its manufacturing factories in Tamil Nadu but also in the States of Telangana, Kerala, Goa, Gujarat and the Union Territory of Puducherry.
Questions Asked by Appellant:
Seeking the present Authority For Advance Ruling (AAR), Tamil Nadu (No. 33/ARA/2025), dated 01.09.2025, the appellant has asked the following questions:
“Question 1: Whether the Applicant can comply with the amended provision of section 2(61) and section 20 of the CGST Act, 2017 as amended by notification 16/2024-Central tax dated 6th August 2024 by following the procedure as stated at para 12 a) to 12 d) of the statement containing the applicant’s interpretation of law (Annexure ‘B’) in terms of Rule 54(1A) of the CGST Rules, 2017.
Question 2: Whether the Applicant can continue to receive the Input Service Invoices issued by the Service Provider/Supplier of Service for the Common Input Service (Which are attributable to one or more State/s) in the name of and addressed to Applicant’s Regular Registration and subsequently transfer the same in terms of Rule 54(1A) of the CGST Rules, 2017 to the MRF HO ISD Registration for subsequent distribution of the common Input Tax Credit through the ISD Mechanism?”
Answer Given by AAR Tamil Nadu:
The authority for advance ruling (AAR) has given the following answers to the questions asked by the appellant:
Answer 1: Through Notification No. 16/2024-Central Tax dated 06.08.2024, an amendment was made to Section 2(61) and Section 20 of the CGST Act, 2017, effective from April 1, 2025. Therefore, the current procedure for receiving and distributing common input services under Rule 54(IA) of the CGST Rules, 2017, is no longer in line with the updated law from April 01, 2025, onwards.
Answer 2: No, the applicant cannot continue to receive the Input Service Invoices issued by the Service Provider/Supplier of Service for the Common Input Service (Which are attributable to one or more states) in the name of and addressed to Applicant’s Regular Registration and subsequently transfer the same in terms of Rule 54(1A) of the CGST Rules, 2017 to the MRF HO ISD Registration for subsequent distribution of the common Input Tax Credit through the ISD Mechanism.
Refer to the official advance ruling for complete information.
Citation: MRF Limited (AAR Tamil Nadu); Advance Ruling No. 33/ARA/2025; 01/09/2025
