2026 (4) TMI 1495

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....g Counsel for R/CGST Mr. Sumit K. Batra and Ms. Priyanka Jindal, Advocates for R-GNCTD. JUDGMENT (ORAL) NITIN WASUDEO SAMBRE, J. 1. The challenge is to the order dated 18th December, 2025, passed by respondent no. 2- State GST Authority, which is based on the Demand-cum-Show Cause Notice dated 2nd July, 2025. 2. Out of the total 17 entities in respect of which respondent no. 4- CGST Authority issued the Show Cause Notice dated 28th June, 2025; respondent no. 2 proceeded to assess the tax liability of the petitioner in respect of 9 entities, which overlapped with the aforesaid Show Cause Notice. 3. Since the Show Cause Notice issued by respondent no. 4 -CGST Authority was prior in point of time, i.e., dated 28th June, 2025, as....

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....submissions, learned counsel for respondent no. 2 states that the law is quite clear on the aforesaid issue. According to him, even if the fact that the petitioner failed to bring the Show Cause Notice and other details issued by respondent no. 4 - CGST Authority to the notice of respondent no. 2 is ignored, the authority can still proceed against the petitioner to the extent of the entities covered under the Show Cause Notice. Further, respondent no. 4 - CGST Authority can, in its proceedings, ignore those entities in respect of which the State Authority has already carried out assessment and adjudication. As such, he has sought dismissal of the present proceedings on the ground that an alternate remedy of appeal is also available to the p....