GST cross-empowerment is limited by taxpayer allocation, and transit detention powers cannot be used beyond the State's taxable nexus.

Cross-empowerment under the GST framework operates only within the limits of taxpayer allocation and assigned function: a State GST officer may exercise corresponding powers under the CGST and IGST laws only for taxpayers administratively allotted to that State, and there is no automatic universal jurisdiction. Transit powers under sections 129 and 130 cannot be used by an intermediary State to detain or confiscate goods in an IGST movement that originates and ends outside the State, particularly where the asserted basis is valuation or quantification at interception. The document states that such proceedings were not sustainable on those grounds, while records could still be forwarded to the proper officers for any lawful action.

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Issues: (i) Whether officers appointed under the Andhra Pradesh GST law could exercise powers under the CGST and IGST enactments by virtue of cross-empowerment, and if so, to what extent in relation to taxpayers administratively allotted to the State. (ii) Whether proceedings under sections 129 and 130 could be sustained in relation to IGST movement of goods originating outside Andhra Pradesh and culminating outside Andhra Pradesh, particularly on grounds of valuation or quantification.

Issue (i): Whether officers appointed under the Andhra Pradesh GST law could exercise powers under the CGST and IGST enactments by virtue of cross-empowerment, and if so, to what extent in relation to taxpayers administratively allotted to the State.

Analysis: The statutory scheme of cross-empowerment operates through the relevant GST provisions and the administrative allocation of taxpayers between Centre and States. An officer appointed under the State enactment becomes a proper officer only for the function assigned and, in respect of the taxpayer allotted to the State, can discharge corresponding functions under the parallel Central and Integrated enactments. The scheme does not confer an unqualified or automatic authority on a State officer to act under the Central or Integrated enactments in the absence of the relevant administrative allocation and functional assignment. The objective is to avoid parallel proceedings and conflicting determinations while preserving the jurisdictional limits of each authority.

Conclusion: Cross-empowerment exists, but only within the limits of taxpayer allocation and assigned function; there is no automatic universal jurisdiction.

Issue (ii): Whether proceedings under sections 129 and 130 could be sustained in relation to IGST movement of goods originating outside Andhra Pradesh and culminating outside Andhra Pradesh, particularly on grounds of valuation or quantification.

Analysis: Sections 129 and 130 are directed to detention, seizure, release, and confiscation by the proper officer in transit cases. Their use cannot be expanded to permit an intermediary State to appropriate penalties or fine in relation to a transaction that does not generate taxable revenue for that State. For IGST movements beginning and ending outside the State, the State officer in Andhra Pradesh cannot exercise confiscatory jurisdiction under sections 129 and 130 merely because the vehicle passed through the State. Further, valuation or quantification disputes at the stage of interception do not justify detention or confiscation unless the statutory conditions for invoking the severe power are otherwise satisfied.

Conclusion: Proceedings under sections 129 and 130 were not sustainable for the impugned IGST inter-State movements on the grounds invoked.

Final Conclusion: The impugned detention and confiscation proceedings were set aside, while the authorities were left free to forward the records to the proper officers concerned for any lawful action.

Ratio Decidendi: Cross-empowerment under the GST framework is confined to the proper officer's assigned function and the taxpayer's administrative allocation, and transit powers under sections 129 and 130 cannot be used by an intermediary State to confiscate or detain goods in an IGST movement wholly outside its taxable nexus or merely to assess valuation disputes at interception.

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