Parallel GST adjudication barred where Central and State authorities act on the same subject matter; coordination required.

Where Central and State GST authorities proceed on the same subject matter, Section 6(2)(b) bars parallel adjudicatory action once proceedings have already commenced by one tax administration. Bona fide investigative steps may continue, but not duplicate adjudication. The High Court required inter-se coordination between the authorities so that only the competent authority carries the matter forward, and directed the taxpayer to place replies and supporting documents before that authority. The authorities were then to decide which administration would continue the proceedings in accordance with Armour Security, without subjecting the assessee to multiplicity of GST adjudicatory action.

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Issues: Whether parallel adjudicatory proceedings by the Central and State GST authorities on the same subject matter were barred, and what directions should govern the petitioner's response to the notices already issued.

Analysis: The proceedings were examined in the light of the binding law declared in Armour Security, which explains that Section 6(2)(b) bars initiation of proceedings on the same subject matter by the other tax administration once adjudicatory proceedings have already commenced, while bona fide investigative steps may continue so long as they do not amount to parallel adjudication. The Court applied those principles to hold that coordination between the authorities was necessary, that the petitioner should place its replies and supporting documents before the competent authority, and that the authorities must determine inter-se which of them would continue the matter without subjecting the assessee to duplicate adjudicatory action.

Conclusion: Parallel adjudicatory proceedings on the same subject matter were not permitted, and the petitioner was directed to respond before the competent authority, after which the Central and State authorities were to coordinate and proceed in accordance with the law declared in Armour Security.

Final Conclusion: The petition was disposed of by protecting the petitioner from multiplicity of GST adjudicatory proceedings and by directing the authorities to coordinate, receive the petitioner's response, and proceed only before the competent authority in accordance with law.

Ratio Decidendi: Where Central and State GST authorities are proceeding on the same subject matter, Section 6(2)(b) prohibits parallel adjudicatory proceedings and requires inter-se coordination so that only one competent authority carries the matter forward to its logical conclusion.

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