Expiry of empowering order under GST renders later proceedings without jurisdiction, and all consequential notices and demands fall.

Proceedings initiated under GST after expiry of the empowering assignment order were held to be without jurisdiction because the officer's authority had lapsed before initiation. The pre-intimation notice, show cause notice, order in original and demand summary, being founded on an invalid assignment, were set aside as consequential actions. The writ petition succeeded, and ancillary relief for de-freezing of bank accounts followed from the invalidity of the underlying proceedings.

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Issues: (i) Whether the assignment to initiate proceedings under the GST law was valid when the empowering order had expired, and whether the consequential proceedings were without jurisdiction; (ii) whether the impugned notice, demand proceedings and order could be quashed.

Issue (i): Whether the assignment to initiate proceedings under the GST law was valid when the empowering order had expired, and whether the consequential proceedings were without jurisdiction.

Analysis: The authority to assign proceedings flowed from an order dated 30 January 2023, which was stated to be operative only up to 31 December 2023. Proceedings were initiated for the 2021-2022 tax period after the expiry of that empowering order. Once the authorising order ceased to operate, the officer lacked authority to make the assignment, and proceedings founded on such an assignment could not stand.

Conclusion: The assignment and the consequential proceedings were without jurisdiction and non-est.

Issue (ii): Whether the impugned notice, demand proceedings and order could be quashed.

Analysis: Since the foundation of the proceedings was held to be invalid, the pre-intimation notice, show cause notice and order in original, along with the summary of demand, were liable to be set aside. The writ jurisdiction was therefore invoked to annul the consequential actions.

Conclusion: The impugned notice, demand proceedings and order were quashed.

Final Conclusion: The proceedings under the GST law failed for want of authority, and the writ petition succeeded with ancillary relief relating to de-freezing of the bank accounts.

Ratio Decidendi: Proceedings initiated by an authority after the expiry of the empowering order are without jurisdiction, and all consequential actions founded on such unauthorised initiation are liable to be quashed.

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