Section 6(2)(b) CGST Act bars the initiation of any proceedings on the same subject matter

The Supreme Court held on 14 August 2025 in the case of M/S Armour Security (India) Ltd vs Commissioner, Cgst, Delhi that Section 6(2)(b) CGST Act bars the “initiation of any proceedings” on the “same subject matter”. Justices J.B. Pardiwala and R. Mahadevan upheld the High Court’s decision and laid down guidelines with reference to the definition of “proceedings” within the scope of Section 6(2)(b) of the CGST Act.

The petitioner which is a public limited company registered under the Companies Act, 2013 engaged in security services, received  a Show Cause Notice (SCN) under Section 73 of the CGST Act for the tax period due to non-reconciliation of turnovers and excess claim of Input Tax Credit (ITC). In a search conducted under Section 67(2) of the CGST Act, electronic gadgets/documents were seized. The petitioner challenged the summons, claiming lack of jurisdiction. 

The Court referred to the ratio in G.K. Trading, wherein the High Court of Allahabad interpreted the phrase “subject matter” to mean ‘cause of action’ in relation to the same dispute in a proceeding before a proper officer under the relevant GST enactment. To exemplify upon the scope of issuing show cause notices, the judgement in Gorkha Security Services v. Govt. (NCT of held that the service of a show cause notice is made in order to inform the noticee about the case that has been set up against him, which he has to meet.

The Supreme Court clarified that parallel proceedings  cannot be initiated by another tax administration when one of the tax administrations has already initiated intelligence-based enforcement action. The bar in Section 6(2)(b) of CGST Act applies only to formal proceedings (SCNs), not searches/summons. Authorities must coordinate to avoid taxpayer harassment and while Central/State authorities can independently investigate, only one can issue an SCN for the same subject matter. This case made an important differentiation between investigation and adjudication, where the latter is barred if parallel.

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Legal Associate Job Mumbai | Saraf and Partners – Apply Now

If you are an ambitious lawyer seeking a dynamic role in corporate law, mergers & acquisitions, and private equity, then this Legal Associate job Mumbai opening at Saraf and Partners could be the perfect career move. With one of India’s fastest-growing independent law firms, this opportunity offers exposure to high-value transactions, global clients, and top-tier corporate advisory work.


About Saraf and Partners

Saraf and Partners is widely recognized as Asia’s fastest-growing independent, professionally owned, and managed law firm. Built on a foundation of expertise and collaboration, the firm works closely with India’s leading corporations and multinational companies exploring opportunities in the Indian market.

The firm is known for:

  • Sector Expertise: Deep knowledge across corporate, M&A, PE, banking & finance, disputes, real estate, and regulatory practice.
  • Clientele: Trusted by top Indian corporations and global giants.
  • Growth-Oriented Culture: Commitment to professional development, diversity, and innovation in legal practice.

For lawyers looking to build a strong corporate law career, Saraf and Partners offers a platform that combines prestige, mentorship, and hands-on deal experience.


About the Job – Legal Associate Role

Saraf & Partners’ Mumbai office is inviting applications for the role of Legal Associate in its General Corporate, Mergers & Acquisitions, and Private Equity practice group. This is an excellent opportunity to work on complex, high-profile deals that shape the Indian and global business landscape.


Practice Areas Covered

The selected candidate will actively contribute to matters in:

  • General Corporate Law – Corporate advisory, regulatory compliance, structuring transactions.
  • Mergers & Acquisitions (M&A) – Drafting and negotiating share purchase agreements, joint ventures, business transfers, due diligence.
  • Private Equity (PE) – Advising on fund investments, exits, restructuring, and investment agreements.

This Legal Associate job Mumbai role is designed for lawyers who enjoy transactional work and strategic client advisory.


Eligibility Criteria

To be considered for this position, candidates must meet the following requirements:

  • Post-Qualification Experience (PQE): 4 to 6 years.
  • Specialization: Demonstrated experience in General Corporate, M&A, and Private Equity.
  • Background: Prior experience working with reputed law firms.
  • Skills:
    • Strong drafting and negotiation abilities.
    • Sound legal research and analytical skills.
    • Effective client communication and management.
    • Ability to work in fast-paced, transaction-heavy environments.

If you have previously worked on complex M&A deals, advised private equity funds, or supported large corporations in strategic transactions, this Legal Associate job in Mumbai will give you the platform to expand your expertise.


Location

  • Office: Saraf and Partners, Mumbai
  • Work Mode: On-site

The Mumbai office is one of the firm’s most active branches, catering to corporate clients, investment funds, and multinational companies.


Skills & Qualities Required

  • Detail-Oriented Drafting: Precision in agreements, contracts, and transactional documentation.
  • Negotiation Skills: Confidence in deal-making, mediating terms, and client representation.
  • Client Management: Professional communication and ability to maintain long-term relationships.
  • Team Collaboration: Ability to work with partners, senior associates, and cross-office teams.
  • Strategic Thinking: Advising clients on commercial feasibility alongside legal compliance.

Why Join Saraf and Partners?

Saraf and Partners is not just another law firm—it is a rapidly expanding platform for ambitious lawyers. Here’s why this Legal Associate job Mumbai stands out:

  • High-Profile Transactions: Work on headline-making deals in M&A and PE.
  • Global Exposure: Collaborate with international clients and cross-border investors.
  • Learning & Development: Mentorship under experienced partners and access to sector-specific expertise.
  • Career Advancement: A growth-oriented firm culture that rewards performance and innovation.
  • Work Environment: Professional, collaborative, and intellectually stimulating.

For lawyers who want to specialize in corporate law, M&A, and private equity, this role offers both immediate challenges and long-term growth.


Application Procedure

Interested candidates can apply by sending their CV to the recruitment team. Make sure your subject line is correctly formatted to avoid missing out.

Applications will be reviewed on a rolling basis, so early submissions are encouraged.


Conclusion

This Legal Associate job Mumbai opportunity at Saraf and Partners is ideal for mid-level lawyers with 4–6 years of PQE who are passionate about corporate advisory, transactions, and deal-making. If you are looking to take the next step in your legal career with a fast-growing law firm, this is your chance to gain unmatched exposure and professional growth.

Apply today and become part of one of Asia’s most dynamic law firms.


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