Overlapping GST proceedings must not be duplicated; the first show cause notice authority should conclude the matter.

Overlapping GST proceedings on the same subject matter should not be pursued in duplicate by different tax administrations. Where one show cause notice has already been issued, that notice-issuing authority must carry the matter to its conclusion; prior inquiries, summons, communications, or information-gathering steps do not shift that responsibility. Other authorities dealing with the same issue should transmit relevant material to the adjudicating authority and inform the taxpayer so an effective reply can be filed. The petitioner was directed to file a reply to the later show cause notice before the competent authority, which was to proceed in accordance with law.

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Issues: Whether, in view of the law on overlapping GST proceedings, the petitioner could seek quashing of multiple communications and a later show cause notice issued on the same subject matter, and which authority was entitled to carry the proceedings forward.

Analysis: The controlling principle applied was that initiation of proceedings on the same subject matter cannot be duplicated by different tax administrations, and that where a show cause notice has already been issued, the authority issuing that notice is to take the matter to its logical conclusion. Prior inquiries, communications, summons, or information-gathering measures do not, by themselves, displace the authority of the first SCN-issuing officer. Other authorities dealing with the same subject matter are to forward relevant material to the adjudicating authority and keep the taxpayer informed so that an effective reply may be filed.

Conclusion: The petitioner was directed to file a reply to the show cause notice dated 11.03.2025 before the competent authority, which was to proceed in accordance with law, while all other authorities were required to conform to the governing directions and transmit relevant material with due intimation to the petitioner.

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