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 Positions Open at Chambers of Deepender Banger

Are you a litigation-focused lawyer eager to deepen your courtroom experience and advance your legal career? The Chambers of Deepender Banger, a well-regarded litigation practice based in Defence Colony, New Delhi, is expanding its team. We are currently inviting applications from passionate, capable, and committed legal professionals to fill two positions for Legal Associates.

This opportunity is ideal for candidates who are passionate about criminal defence litigation and aspire to practice regularly before the Hon’ble Supreme Court of India and various High Courts across the country.

About the Chambers of Deepender Banger

The Chambers of Deepender Banger is a litigation chamber committed to high-impact criminal defence and constitutional advocacy. Our work spans across trial strategy, appellate litigation, bail matters, and legal reform, focusing heavily on representation before the Hon’ble Supreme Court of India and several High Courts.

Our chamber culture emphasizes in-depth legal research, precise drafting, and vigorous courtroom advocacy. Associates here benefit from direct mentorship, exposure to live hearings, and participation in landmark cases.

Position Details

Role: Legal Associate
Location: Defence Colony, New Delhi
Positions Open: 2
Practice Area: Criminal Defence Litigation (Supreme Court & High Courts)
Experience Required: 3–4 years of Post-Qualification Experience (PQE)
Salary & Perks: Competitive and commensurate with industry standards

What We’re Looking For

We are seeking legal professionals who are not just qualified, but courtroom-ready. You should have experience in handling criminal matters, bail hearings, writs, and drafting SLPs, rejoinders, and legal opinions.

Ideal Candidate Profile:

  • Law graduate with 3–4 years of post-qualification litigation experience
  • Proficiency in criminal law, procedural law, and constitutional issues
  • Prior appearance experience before High Courts and/or the Supreme Court
  • Excellent legal research and drafting skills
  • Strong oral and written communication
  • A disciplined, ethical, and team-oriented mindset
  • Ability to handle matters independently under supervision

Key Responsibilities

  • Conduct legal research on complex issues in criminal and constitutional law
  • Draft Special Leave Petitions (SLPs), counter affidavits, bail applications, writ petitions, and case notes
  • Appear before courts (primarily Supreme Court and High Courts) alongside senior counsels
  • Coordinate with briefing counsels, clerks, and clients
  • Maintain regular case updates, filing timelines, and court schedules
  • Prepare case summaries, briefs, and arguments for hearings

What You’ll Gain

Joining the Chambers of Deepender Banger offers a dynamic and intellectually enriching litigation environment. Here, you will not only learn but actively participate in high-stakes defence strategies, interact with senior counsels, and be involved in shaping impactful legal arguments.

You will also build a professional portfolio of meaningful cases, while being mentored in courtroom advocacy, legal ethics, and procedural rigor.

How to Apply

If you meet the criteria and are looking for a long-term role that strengthens your courtroom foundations, we encourage you to apply.

Last Date to Apply: 30 June 2025
Email: dsb@deependerbanger.com

Documents Required:

  • Updated Resume (PDF preferred)
  • Cover Letter detailing your experience, interest in criminal defence, and future goals

Use the subject line: Application – Legal Associate – [Your Name]

Final Word

The Chambers of Deepender Banger is not merely offering a job—it is extending an opportunity to be part of a thriving legal practice committed to excellence in litigation and advocacy. Joining our team means stepping into a dynamic, intellectually stimulating environment where your legal acumen will be sharpened through direct courtroom exposure, challenging assignments, and active mentorship.

We are seeking dedicated legal professionals with 3–4 years of hands-on litigation experience—individuals who are passionate about the law, eager to engage in meaningful legal work, and prepared to contribute actively to complex cases across various practice areas. Here, you won’t just assist; you’ll advocate, argue, draft, and grow into a well-rounded litigation professional. Apply now and take a decisive step toward becoming a confident, accomplished courtroom advocate.


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