Customs-led IGST assessment limits State GST jurisdiction, while GST cross-empowerment cannot override taxpayer allocation.

IGST on imported goods is assessed and collected through the customs framework, so a State GST officer cannot assume jurisdiction over import-related IGST demands. The GST cross-empowerment scheme operates only within statutory limits and proper officer allocation; it does not authorise a State officer to proceed against a taxpayer administratively allotted to the Central jurisdiction. A notice that extends beyond the original intimation, adds fresh issues, or covers multiple years is procedurally impermissible on the stated facts and cannot be sustained where the initiating officer lacked jurisdiction.

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Issues: (i) Whether a State GST officer had jurisdiction to initiate and continue proceedings for IGST on imported goods, where the levy and collection arise at the stage of customs assessment; (ii) whether cross-empowerment under the GST framework enabled a State GST officer to proceed against a taxpayer administratively allotted to the Central jurisdiction; (iii) whether the impugned notice could survive when it travelled beyond the original intimation and covered multiple years and issues.

Issue (i): Whether a State GST officer had jurisdiction to initiate and continue proceedings for IGST on imported goods, where the levy and collection arise at the stage of customs assessment.

Analysis: The levy on imported goods is governed by the IGST framework read with the customs law provisions that link IGST collection to customs duty assessment at the point of import. The statutory scheme shows that the determination of duty, tax, cess or other sums on imported goods is carried out by the customs machinery, including assessment and recovery provisions under the Customs Act. Since the IGST on imports is collected in accordance with the customs valuation and levy mechanism, the officer empowered under the State GST regime could not assume jurisdiction over that subject matter.

Conclusion: The jurisdiction to assess and collect IGST on imported goods lay with the customs authorities, not with the State GST officer.

Issue (ii): Whether cross-empowerment under the GST framework enabled a State GST officer to proceed against a taxpayer administratively allotted to the Central jurisdiction.

Analysis: The cross-empowerment provisions permit State and Central officers to act as proper officers only within the limits created by the statutory scheme and the notified allocation of taxpayers. Where proceedings on the same subject matter are already initiated by one side, the other side cannot independently proceed, and the officer must also be the proper officer for the taxpayer concerned. As the taxpayer had been administratively allotted to the Central jurisdiction, the State GST officer could not invoke cross-empowerment to assume authority in the matter.

Conclusion: Cross-empowerment did not confer jurisdiction on the State GST officer in respect of a taxpayer allotted to the Central jurisdiction.

Issue (iii): Whether the impugned notice could survive when it travelled beyond the original intimation and covered multiple years and issues.

Analysis: The later notice went beyond the scope of the earlier intimation by introducing additional matters and covering multiple years. A notice of that kind was treated as impermissible in the light of the governing procedural principles applied by the Court. Once the foundational notice itself was without jurisdiction, the expanded notice could not be sustained on the wider issues also raised therein.

Conclusion: The impugned notice was unsustainable on this ground as well.

Final Conclusion: The proceeding was quashed in relation to the imported-goods IGST demand, and the petitioner obtained complete relief from the impugned notice.

Ratio Decidendi: IGST on imported goods is to be assessed and collected through the customs framework, and cross-empowerment under GST cannot be used by a non-jurisdictional State officer to proceed against a taxpayer allotted to the Central jurisdiction.

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