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    <title>WHEN TWO AUTHORITIES PURSUE ONE LIABILITY - THE GST DOCTRINE AGAINST PARALLEL PROCEEDINGS</title>
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    <description>Parallel GST adjudicatory proceedings are barred where two authorities seek to pursue substantially the same liability on the same alleged contravention, but investigative steps such as summons, searches, seizures, inspections, and evidence collection do not by themselves amount to initiation of proceedings. Formal proceedings commence with a Show Cause Notice, which defines the scope of the alleged violation and proposed liability; the restriction in Section 6(2)(b) of the CGST Act is directed against duplicate adjudication, not legitimate inquiry or fact-finding. The expression same subject matter is confined to the liability and contravention actually under examination, and distinct infractions are not treated as the same subject matter merely because the taxpayer is common or the financial impact appears similar.</description>
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    <pubDate>Thu, 14 May 2026 09:01:44 +0530</pubDate>
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      <description>Parallel GST adjudicatory proceedings are barred where two authorities seek to pursue substantially the same liability on the same alleged contravention, but investigative steps such as summons, searches, seizures, inspections, and evidence collection do not by themselves amount to initiation of proceedings. Formal proceedings commence with a Show Cause Notice, which defines the scope of the alleged violation and proposed liability; the restriction in Section 6(2)(b) of the CGST Act is directed against duplicate adjudication, not legitimate inquiry or fact-finding. The expression same subject matter is confined to the liability and contravention actually under examination, and distinct infractions are not treated as the same subject matter merely because the taxpayer is common or the financial impact appears similar.</description>
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      <pubDate>Thu, 14 May 2026 09:01:44 +0530</pubDate>
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