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 โ€œinitiation of any proceedingsโ€ on the โ€œsame subject matterโ€. Justices J.B. Pardiwala and R. Mahadevan upheld the High Courtโ€™s decision and laid down guidelines with reference to the definition of โ€œproceedingsโ€ 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 โ€œsubject matterโ€ to mean โ€˜cause of actionโ€™ 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.

Join Our WhatsApp Channel for Opportunity Updates

Get Daily Updates

Join our Telegram Channel for Opportunity Updates

Get Daily Updates

Leave a Reply

Your email address will not be published. Required fields are marked *

Next Article

Legal Interns | Chambers for Justice (Hybrid Internship โ€“ Delhi Preferred)

Legal Interns | Chambers for Justice (Hybrid Internship โ€“ Delhi Preferred)

Organization Overview:
Chambers for Justice is a dynamic and forward-looking law firm, dedicated to providing innovative and practical legal solutions with a client-centric approach. The firm specializes in litigation, research, and advisory services, offering robust support to clients while emphasizing fairness, justice, and ethical practice. With a commitment to delivering high-quality legal services, Chambers for Justice ensures interns gain hands-on experience across multiple practice areas and exposure to real-world legal challenges.

The firmโ€™s ethos revolves around nurturing talent, encouraging analytical thinking, and providing a platform where aspiring lawyers and legal interns can develop professional skills under the guidance of experienced practitioners. Chambers for Justice is particularly known for its structured internship programs designed to provide practical insights into litigation, drafting, client handling, and case management processes.

Location:

  • Hybrid Internship โ€“ Delhi-based students preferred
  • Flexible work arrangements with a combination of remote support and in-office tasks depending on availability

Position / Duration:

  • Legal Internship for 1 Month, extendable based on performance and mutual consent
  • Working Days: Monday to Saturday
  • Work Timings: 9:30 AM โ€“ 5:00 PM

Eligibility Criteria:

  • Currently enrolled in a 3-year or 5-year LL.B. program from a recognized university in India
  • Strong analytical, research, and problem-solving abilities
  • Effective written and verbal communication skills
  • Prior internship experience in law firms, legal research organizations, or corporate legal departments is advantageous but not mandatory
  • Preference will be given to final-year students due to the advanced level of tasks involved
  • Ability to commit to the full duration of the internship and deliver quality work

Key Responsibilities:
Interns will actively participate in several core legal functions, gaining practical exposure across multiple areas of law. Responsibilities include:

  • Conducting detailed legal research, analyzing case laws, statutes, and legal precedents to support ongoing litigation and advisory projects
  • Preparing case summaries, briefs, and reports to assist senior lawyers in case strategy development
  • Drafting legal documents, notices, agreements, and other correspondences under the supervision of experienced legal professionals
  • Maintaining organized case files, ensuring that all documentation is properly filed and updated
  • Coordinating with clients, collecting relevant information, and assisting in the preparation of case-related materials
  • Attending hybrid meetings, client consultations, or internal strategy sessions as required

This internship is structured to provide interns with a comprehensive understanding of law practice management, court procedures, and client servicing. Interns will learn not only the technical aspects of legal work but also professional skills such as time management, teamwork, client interaction, and strategic thinking.

Number of Positions Available: 10

Stipend & Perks:

  • This is an unpaid internship; however, interns will receive extensive practical exposure and mentorship
  • Opportunity to work closely with experienced lawyers on real cases and legal projects
  • Gain hands-on experience in litigation, drafting, legal research, and client handling
  • Certificate of Internship provided upon successful completion, highlighting the skills and exposure gained

Learning Outcomes:
By the end of the internship, participants will be able to:

  • Conduct independent legal research and draft professional legal documents
  • Prepare case briefs and summaries with clarity and precision
  • Understand the dynamics of litigation and advisory work in a hybrid law firm environment
  • Gain exposure to court proceedings, client interactions, and strategic legal planning
  • Develop practical knowledge of procedural law, statutory interpretation, and case law analysis

Application Process:
Applicants are requested to submit their CV along with a brief statement of interest, highlighting their educational background, skills, and motivation for joining the internship. The application should demonstrate a clear understanding of the responsibilities and the willingness to engage in a professional legal environment.

Last Date to Apply: 31st August 2025

How to Apply:
Submit your CV and statement of interest via the https://lnkd.in/g-zHuxeV

Applicants are requested to submit their CV along with a brief statement of interest.


Join Our WhatsApp Channel for Opportunity Updates

Get Daily Updates

Join our Telegram Channel for Opportunity Updates

Get Daily Updates

Next Article

Contact Us

For Submitting a Post

contact@lawdrishti.com

For Banner ads & admission campaigns

advertise@lawdrishti.com

Timing

Hours: 9 AM โ€“ 9 PM (Mon-Sat)

See the below animation to allow notifications.

Start getting Lawdrishti updates useful for you!

Contact Us

For Submitting a Post

For Banner ads & admission campaigns

Contact us
For Submitting a Post
For Banner ads & admission campaigns
Timing

Hours: 9 AM โ€“ 9 PM (Mon-Sat)