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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Virtual Internship in Intellectual Property Rights – Apply at NUSRL Ranchi (CSRIPR)

Virtual Internship in Intellectual Property Rights – Applications Open at NUSRL Ranchi (CSRIPR)

Are you passionate about Intellectual Property Rights (IPR)? Looking to gain meaningful virtual research experience with one of India’s premier law schools? Here’s your chance. The Centre for Study and Research in Intellectual Property Rights (CSRIPR) at the National University of Study and Research in Law (NUSRL), Ranchi, is inviting applications for its upcoming Virtual Internship in Intellectual Property Rights, scheduled to be held from September 1 to September 30, 2025.

This internship program is a golden opportunity for students of law and science alike to explore IPR and its emerging socio-legal, scientific, and technological dimensions. If you’re ready to deep-dive into the world of patents, copyrights, trademarks, and indigenous knowledge systems, this is the right platform for you.

About the Program

The Virtual Internship in Intellectual Property Rights at CSRIPR, NUSRL Ranchi, is designed to cultivate research, policy analysis, and practical insights in the field of IPR. Whether you are a budding legal scholar or a science student curious about the legal aspects of innovation, this internship equips you with foundational and advanced exposure.

Organization

  • Host Institution: National University of Study and Research in Law (NUSRL), Ranchi
  • Department: Centre for Study and Research in Intellectual Property Rights (CSRIPR)
  • Internship Mode: Online / Virtual
  • Duration: September 1 – September 30, 2025
  • Stipend: Not specified

Eligibility Criteria

This Virtual Internship in Intellectual Property Rights is open to a diverse group of students, both from law and science backgrounds, nationally and internationally.

Law Students:

  • Undergraduate or postgraduate students pursuing LLB, BA LLB, BBA LLB, LLM, etc.

Non-Law Students (Limited to 10 seats):

  • Students from scientific and allied disciplines, including but not limited to:
    • B.Tech / M.Tech
    • BSc / MSc
    • MBBS / MS / MD
  • Candidates must demonstrate a keen interest in IPR and its socio-legal dimensions.

The internship promotes interdisciplinary collaboration, aiming to bridge the gap between science, technology, and law.

Key Responsibilities

As an intern under this Virtual Internship in Intellectual Property Rights, you will:

  • Conduct in-depth research on IPR topics including:
    • Patent law
    • Copyrights
    • Trademarks
    • Geographical Indications
    • Trade secrets
    • IPR in biotechnology, software, indigenous knowledge, etc.
  • Collaborate on academic projects, policy reviews, and comparative law studies.
  • Participate in IPR awareness initiatives and virtual seminars/webinars.
  • Explore the legal implications of technology transfer and standardization.
  • Work on case studies related to IP disputes and innovation law.

This internship is structured to offer real-world exposure to how IPR laws are researched, interpreted, and implemented in both domestic and international contexts.

Important Dates

Make sure you don’t miss the key deadlines for this Virtual Internship in Intellectual Property Rights:

  • Last Date to Apply: August 15, 2025
  • Interview Date (Tentative): August 22, 2025
  • Shortlisted Candidates Announcement: August 28, 2025
  • Internship Confirmation Deadline: August 30, 2025
  • Internship Period: September 1 – September 30, 2025

Application Process

To apply for this Virtual Internship in Intellectual Property Rights at NUSRL Ranchi:

  1. Fill the Official Google Form before August 15, 2025.
    (The form link is not provided in the listing. Please refer to the official website or email for access.)
  2. Keep your resume, academic transcripts, and a short Statement of Purpose (SOP) ready.
  3. Highlight your interest or experience in IPR in your SOP or cover letter.

For Queries & Contact:
Email: csripr@nusrlranchi.ac.in

Why Join the Virtual Internship in Intellectual Property Rights at NUSRL?

Flexible Online Mode – Attend from anywhere in the world
Interdisciplinary Focus – Learn how law intersects with innovation and technology
Learn from Experts – Interact with IPR scholars, practitioners, and guest speakers
Certificate on Completion – Boost your CV and academic portfolio
Policy-Relevant Experience – Work on projects with real-world implications

This internship fosters academic excellence, professional growth, and interdisciplinary knowledge-sharing.

Pro-Tips for Applicants

  • Submit your application early to avoid last-minute delays.
  • Show your interest in emerging domains such as Artificial Intelligence & IPR, Patent Law in Pharmaceuticals, or Technology Licensing.
  • Keep a sample of your past academic writing or research work ready – it may be requested.
  • Be available for interviews around the tentative date (August 22).

Conclusion

This Virtual Internship in Intellectual Property Rights offered by CSRIPR, NUSRL Ranchi, is a rare and valuable opportunity to explore the complex yet fascinating world of intellectual property law. Open to both law and science students, it’s designed to build a solid foundation in research, legal analysis, and interdisciplinary collaboration.

Whether you aim to become a legal expert in patent law or want to understand how your scientific innovation is protected by law, this internship is a step in the right direction.

Apply now and join the September 2025 cohort to kickstart your journey into the world of Intellectual Property Rights.
Deadline: August 15, 2025
Contact: csripr@nusrlranchi.ac.in


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