Inquiry/investigation into tax evasion renders advance ruling application inadmissible.

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....Proceedings under the CGST Act, 2017 encompass not just judicial proceedings but also assessment, audit, detention/seizure/release of goods and conveyances, even if they do not culminate in a show cause notice. Investigation or inquiry initiated to safeguard government revenue qualifies as proceedings. The applicant's contention that inquiry/investigation does not constitute proceedings is misconceived. Since investigation by DGGI predated the applicant's advance ruling application on the same issue, the application is liable for rejection under the first proviso to Section 98(2) of the CGST/TNGST Acts, 2017. Consequently, the advance ruling application is rejected.....