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of <h1>Issuance of summons, searches or seizures not 'initiation of proceedings' under Section 6(2)(b) CGST Act; show cause notice starts proceedings</h1> The Supreme Court held that issuance of summons, searches or seizures are pre-adjudicatory investigative steps and do not constitute 'initiation of proceedings' under Section 6(2)(b) of the CGST Act; formal proceedings commence with a show cause notice, which alone delineates the 'subject matter.' The Court adopted a twofold test for identity of subject matter-whether the alleged liability/offence arises from the same facts and whether the demand or relief sought is identical or overlapping-and permitted intelligence-based enforcement by either Centre or State while barring parallel adjudicatory proceedings on the same subject matter. It directed administrative coordination, material sharing, and IT-enabled data exchange to avoid duplication.
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