AAR ruling of another distinct GSTIN holder even under same brand can't be applied bindingly to a different GSTIN holder with an independent business

Last updated: 04 October 2025

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The Madhya Pradesh High Court has ruled that an Advance Ruling (AAR) issued for one GSTIN holder cannot be automatically applied to another independent business with a different GSTIN, even if they share the same brand. The court emphasised that tax authorities must independently examine the facts of each case rather than mechanically relying on previous AARs. Consequently, a demand order based solely on a non-binding AAR was quashed, and the case was remitted for a fresh, reasoned decision.

Court :
Madhya Pradesh High Court

Brief :
The Hon'ble Madhya Pradesh High Court in the case of Mahendra Singh v. Assistant Commissioner State Tax & Ors. [Writ Petition No. 5186/2025, order dated September 10, 2025] held that an Advance Ruling (AAR) issued in the name of another distinct GSTIN holder cannot be mechanically applied to a different GST-registered person, and the adjudicating authority must independently examine the facts of the case instead of relying on non-binding precedent.

Citation :
Writ Petition No. 5186/2025, order dated September 10, 2025

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1 Year PLAN

1999

(Excl. of GST ₹359)

2 Years PLAN

3499

(Excl. of GST ₹629)

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3 Years PLAN

4999

(Excl. of GST ₹899)

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Attached File : 671907_5876_mahendra_singh.pdf

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Judgement posted by

Bimal Jain

Service

FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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