M/S ARMOUR SECURITY (INDIA) LTD. versus COMMISSIONER, CGST, DELHI EAST COMMISSIONERATE & ANR.

M/S ARMOUR SECURITY (INDIA) LTD. versus COMMISSIONER, CGST, DELHI EAST COMMISSIONERATE & ANR.

The Supreme Court held that a summons, search or inquiry for the purpose of gathering information does not constitute 'initiation of any proceedings' under Section 6(2)(b) of the CGST Act; the initiation of proceedings for the purposes of s.6(2)(b) occurs with the issuance of a show cause notice which crystallises...

Source-derived case information.

Parties
Petitioner: M/s Armour Security (India) Ltd.; Respondent: Commissioner, CGST, Delhi East Commissionerate & Anr.
Jurisdiction
India
Judgment Date
14 August 2025
Procedural Posture
Special Leave Petition (c) No. 6092 of 2025 / Disposed
Outcome
Special Leave Petition dismissed and petition disposed of
Legal Topics
Section 6(2)(b) CGST, Section 70 CGST, Summons, Show Cause Notice, Cross Empowerment, Intelligence Based Enforcement, Single Interface, Parallel Proceedings, Subject Matter
Central Goods and Services Tax Act, 2017 Tax Law Administrative Law Section 6(2)(b) CGST Section 70 CGST Summons Show Cause Notice Cross Empowerment +4 more

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Parties

M/s Armour Security (India) Ltd.

Petitioner

Commissioner, CGST, Delhi East Commissionerate & Anr.

Respondent

Procedural Posture

Special Leave Petition (c) No. 6092 of 2025 / Disposed

Legal Issues

  1. 1 Whether issuance of summons can be regarded as initiation of proceedings within the meaning of Section 6(2)(b) of the CGST Act
  2. 2 Whether 'subject matter' within the meaning of Section 6(2)(b) includes all matters dealt with in summons under the Act
  3. 3 What is the purport of an 'order' under Section 6(2)(a) of the CGST Act

Ratio Decidendi

The Supreme Court held that a summons, search or inquiry for the purpose of gathering information does not constitute 'initiation of any proceedings' under Section 6(2)(b) of the CGST Act; the initiation of proceedings for the purposes of s.6(2)(b) occurs with the issuance of a show cause notice which crystallises the subject matter (liability alleged), and the bar in s.6(2)(b) is attracted only where two proceedings seek to assess or recover an identical or overlapping tax liability arising from the same contravention.

Court Disposition

Special Leave Petition dismissed and petition disposed of

Orders

  • Present petition disposed of
  • Pending application(s), if any, disposed of