Issuing summons not 'initiation of proceedings' under Section 6(2)(b) - formal start requires service of show cause notice

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....SC held that issuance of summons does not amount to the "initiation of any proceedings" under Section 6(2)(b) of the CGST Act; formal initiation occurs upon service of a show cause notice delineating the subject matter. The Court construed "subject matter" as the specific tax liability, deficiency or obligation framed in adjudicatory proceedings and held that overlapping or investigative acts (summons, search, seizure) do not ipso facto create identical subject matter attracting the bar in Section 6(2)(b). Section 6(2)(a) requires a proper officer issuing an order under the CGST Act to communicate a corresponding order to the State/UT counterpart to prevent multiplicity of proceedings. Petition disposed.....