Whether parallel audit/search proceedings are valid when proceedings are already initiated by other tax authorities ?
TRT-2026-1782

Issue Favourable to Tax Payer ?:- yes

Held - The Apex Court, in Armour Security case, has held that once one authority—Central or State—has initiated proceedings first in point of time, any subsequent parallel adjudicatory proceedings on the same cause of action by the other authority are barred under Section 6(2)(b). The Apex Court has emphasized the need to avoid overlapping proceedings and multiplicity, while at .....

TRT-2026-1764

Issue Favourable to Tax Payer ?:- yes

Held - Upon hearing the learned counsel on either side, I am satisfied that, in respect of the same tax period, namely, 2021–2022, both the impugned orders have been passed. Hence, there cannot be two orders covering the same discrepancies in respect of the same petitioner for the same assessment year.

In view thereof, the impugned order dated 09.10.2025, wh.....

TRT-2026-1771

Issue Favourable to Tax Payer ?:- yes

Held - The Apex Court, in Armour Security case, has held that once one authority—Central or State—has initiated proceedings first in point of time, any subsequent parallel adjudicatory proceedings on the same cause of action by the other authority are barred under Section 6(2)(b). The Apex Court has emphasized the need to avoid overlapping proceedings and multiplicity, while at the s.....

TRT-2026-1451

Issue Favourable to Tax Payer ?:- yes

Held - By virtue of cross-empowerment under Section 6(1) of the GST Act the State Proper Officer and the Central Proper Officer are appointed for all the purpose of the CGST Act and the OGST Act. Taking into consideration the events enumerated above, it is apparent that the exercise of power under Section 74 by the State Proper Officer based on the intelligence received is before the initiation of proceeding by the.....

TRT-2026-1419

Issue Favourable to Tax Payer ?:- no

Held: At the stage of issuing a summons, the Department is yet to determine whether proceedings should be initiated against the assessee. Such evidence-gathering and inquiry do not constitute “proceedings” within the meaning of Section 6(2)(b) of the CGST Act. The mere issuance of a summons cannot be equated with proceedings barred under the Act, as the subject matter cannot be ascertained solely throug.....

TRT-2026-1406

Issue Favourable to Tax Payer ?:- yes

Held - From a perusal of the orders, it would further transpire that an enforcement case was initiated to verify the veracity of the claim made by the petitioner as regards exempted/nil rated supply and it is pursuant thereto that three several orders have been passed. Insofar as the show cause notice issued by the CGST authorities dated 19th December, 2023 is concerned, I find that the same has been initiated for .....

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