The petitioner, M/s Armour Security (India) Ltd., engaged in providing security services, challenged the summons issued by the Central GST authorities under Section 70 of the CGST Act, 2017. Earlier, the State GST authority had issued a show-cause notice for the same tax period (April 2020–March 2021) regarding non-reconciliation of turnover and excess input tax credit (ITC) claims. Subsequently, the Central GST authorities conducted a search and issued separate summons for production of documents.

The petitioner contended that the Central authority lacked jurisdiction to issue such summons since proceedings on the same subject matter had already been initiated by the State authority, invoking the bar under Section 6(2)(b) of the CGST Act. The Delhi High Court dismissed the writ petition, holding that issuance of summons was merely an investigative step, not initiation of proceedings.

The Supreme Court upheld the Delhi High Court’s decision, ruling that the issuance of summons under Section 70 of the CGST Act does not amount to “initiation of proceedings” under Section 6(2)(b). The Court clarified that “proceedings” in the said provision refer to adjudicatory actions such as assessment, demand, or penalty proceedings under Sections 73 or 74, and not preliminary steps like searches or investigations.

The Court harmonized various High Court decisions and emphasized that Section 6(2)(b) seeks to prevent dual adjudication, not parallel investigations. It concluded that inquiries by Central authorities are valid even where the State authorities have commenced proceedings on a similar issue, provided no adjudicatory overlap occurs. Consequently, the petition was dismissed.