Parallel GST proceedings on the same liability and suppliers cannot stand where adjudication duplicates earlier State action.

A bona fide mistake in the prayer portion of a writ petition, where only the date of the impugned adjudication order needed correction, justified amendment because no prejudice was shown and procedural technicalities could not defeat the application. The Court also held that a GST adjudication could not be sustained where it substantially duplicated earlier State GST proceedings on the same allegations, liability, and suppliers. Once material overlap was established, parallel adjudication of the same contravention was impermissible, and the impugned order was set aside.

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Issues: (i) Whether the amendment of the prayer portion of the writ petition, to correct the date of the impugned adjudication order, should be allowed. (ii) Whether the impugned adjudication order could be sustained in law in view of the earlier proceedings initiated by the State GST Authority on the same allegations and against substantially the same suppliers.

Issue (i): Whether the amendment of the prayer portion of the writ petition, to correct the date of the impugned adjudication order, should be allowed.

Analysis: The incorrect mention of the date was found to be a bona fide error. The amendment was sought only to correct the date of the impugned order in the prayer portion, and no prejudice was shown that would justify insistence on procedural formalities or technical requirements.

Conclusion: The amendment application was allowed.

Issue (ii): Whether the impugned adjudication order could be sustained in law in view of the earlier proceedings initiated by the State GST Authority on the same allegations and against substantially the same suppliers.

Analysis: The Court relied on the law governing overlapping inquiries and parallel proceedings under the GST regime. It noted that where the same taxable liability, contravention, and suppliers are already the subject of proceedings by one authority, a subsequent show-cause notice or adjudication on the same subject matter cannot stand. The materials showed substantial overlap between the State proceedings and the Central adjudication, with common suppliers and common allegations. In the absence of proof that the prior State proceedings and orders had been furnished to the Central authority, the impugned order was nevertheless held unsustainable once the overlap was established.

Conclusion: The impugned adjudication order was set aside.

Final Conclusion: The writ petition succeeded, the challenged adjudication was quashed, and the connected applications were disposed of in consequence.

Ratio Decidendi: A subsequent GST proceeding cannot be sustained where it duplicates an earlier proceeding on the same subject matter and against the same liability, since overlapping jurisdiction must not result in parallel adjudication of the same contravention.

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