2025 (10) TMI 1175

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....of 2025 - -<br>GST<br>Honourable Mr. Justice C. Saravanan For the Petitioner : Mr. C. Bosco For the R1 : Mr. V. Prashanth Kiran Government Advocate For the R2 : Mr. R.P. Pragadish Senior Standing Counsel ORDER Mr.V.Prashanth Kiran, learned Government Advocate, takes notice for R1. Mr.R.P.Pragadish, learned Senior Standing Counsel, takes notice for R2. 2. Heard the learned counsel....

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....he learned counsel for the petitioner would submit that the dispute arose only on account of a mismatch between the tax amount reflected in GSTR-7 and the monthly returns filed by the petitioner in GSTR1/GSTR 3B for the tax period 2018-2019. 7. It is submitted that in respect of the demand confirmed by the Orderin- Original No.15/2024-GST(ADC) dated 28.03.2024, the 1st respondent has now issued....

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....overed by the decision of the Hon&#39;ble Supreme Court in M/S Armour Security (India) Pvt Ltd v. Commissioner, CGST, Delhi East Commissionerate & Anr. [Special Leave Petition (C) No. 6092 of 2025 dated 14.08.2025]. 11. The learned Government Advocate, specifically, drawn the attention of the Court to sub clause iv, ix and x in Paragraph No.96 of the aforesaid decision, which reads as under: ....

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....lel proceedings cannot be initiated by one tax administration when another tax administration has already commenced action. Further, the court held that where the proceedings concern distinct infractions, the same would not constitute a "same subject matter" even if the tax liability, deficiency, or obligation is same or similar, and the bar under Section 6(2)(b) would not be attracted. 13. It ....