Classification and rate disputes are a common source of GST demands, especially in departmental audits. A written opinion examines the tariff entries, chapter notes, notifications, circulars and advance rulings to arrive at the correct classification.
Tax opinion, Income Tax and GST
What the opinion covers
Where the issue is genuinely debatable, the opinion also discusses the option of an advance ruling and the risk of each position.
Typical questions
- New product or service
- Department audit raising a classification issue
- Composite or mixed supply questions
Timeline
Agreed at engagement, depending on research required.
Information we need
- Product literature, composition and use
- Invoices and contracts
- Any department correspondence
How we work
- Study the product or service and its use
- Analyse tariff entries, notifications and rulings
- Deliver an opinion with conclusion and risk assessment
Please note
- Advance rulings bind only the applicant and the jurisdictional officer
What usually comes next
- GST Advance Ruling Application – ChhattisgarhGetting a binding advance ruling
- GST Departmental Audit (ADT-01 / ADT-02) SupportClassification issues in GST audit
Frequently asked questions
Can the opinion be used in a dispute?
The analysis can support your reply, but the binding position comes only from an advance ruling or an appellate order.
Official sources
- Income Tax Departmentincometaxindia.gov.inActs, rules, circulars and the 1961 to 2025 section utility
- CBIC – GSTcbic-gst.gov.inCGST Act, rules, notifications and circulars
Received a notice or an order?
Call us to talk it through. Keep the notice and its response date handy.