Section 6 is the hinge of GST's dual administration. State and UT officers are proper officers for CGST too, an order by one administration carries the other's tax with it, and once one side has begun proceedings on a subject matter the other may not begin its own.
Key points
- Under section 6(1) of the CGST Act, 2017, officers appointed under the State GST Acts and the UTGST Act are authorised to be proper officers for the CGST Act, subject to conditions notified on the GST Council's recommendation.
- An order by a proper officer under the CGST Act must be matched by an order under the State or UT Act (section 6(2)(a)), so one order covers both taxes.
- Once a State or UT proper officer has initiated proceedings on a subject matter, a central officer may not initiate proceedings on the same subject matter (section 6(2)(b)).
- In Armour Security (India) Ltd v Commissioner, CGST (2025) the Supreme Court held that a summons or search is not "initiation of proceedings"; the bar applies from a show cause notice, and only where both sides pursue the same liability on the same facts.
The provisions
6(1)State and UT officers as proper officers for CGST
Statutory text
(1) Without prejudice to the provisions of this Act, the officers appointed under the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act are authorised to be the proper officers for the purposes of this Act, subject to such conditions as the Government shall, on the recommendations of the Council, by notification, specify.
*Enforced w.e.f. 1st July 2017.
6(2)One order for both taxes; no parallel proceedings
Statutory text
(2) Subject to the conditions specified in the notification issued under sub-section (1),-
(a) where any proper officer issues an order under this Act, he shall also issue an order under the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act, as authorised by the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act, as the case may be, under intimation to the jurisdictional officer of State tax or Union territory tax;
(b) where a proper officer under the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act has initiated any proceedings on a subject matter, no proceedings shall be initiated by the proper officer under this Act on the same subject matter.
What it means
Clause (a) avoids two orders on one transaction: a central proper officer's order is accompanied by the corresponding State or UT order, under intimation to the jurisdictional officer of the other side.
Clause (b) is the bar on parallel proceedings. It turns on two questions — when proceedings are "initiated", and when the subject matter is "the same". The Supreme Court answered both in Armour Security.
Case on this provision
Armour Security (India) Ltd v Commissioner, CGST, Delhi East Commissionerate
2025 INSC 982 · 14.08.2025 · Supreme Court, 2 Judges (J.B. Pardiwala, R. Mahadevan JJ.)
- Facts
- The State GST authority issued a show cause notice under section 73 for 2020–21 alleging under-reported tax and excess credit. Central GST officers then searched the company's premises under section 67 and summoned its directors under section 70. The company argued that section 6(2)(b) barred the central action.
- Held
- Appeal dismissed. Summons, search and investigation are steps of inquiry, not the "initiation of any proceedings"; for section 6(2)(b), proceedings are initiated by a show cause notice. The subject matter is "the same" only if both authorities pursue the same liability on the same facts and seek the same demand or relief. The Court directed that summons be issued in accordance with the CBIC guidelines and not as a routine.
- Here
- Both sides may investigate; once one issues a show cause notice on a liability, the other may not adjudicate the same liability.
Indo International Tobacco Ltd v Vivek Prasad, ADG, DGGI — Delhi High Court, 11.01.2022— Investigations by several authorities may be consolidated under one; section 6(2)(b) does not bar it.
W.P.(C) 2420/2021 and connected matters, Manmohan and Navin Chawla JJ. Several CGST, State and DGGI units had searched entities in an alleged fake-credit network; DGGI's Ahmedabad zonal unit took over all the investigations. The High Court held that the Act does not prohibit transfer or consolidation of investigations with a common link, and dismissed the petitions.
6(3)Rectification, appeal and revision
Statutory text
(3) Any proceedings for rectification, appeal and revision, wherever applicable, of any order passed by an officer appointed under this Act shall not lie before an officer appointed under the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act.
What it means
An order passed by a central officer is rectified, appealed or revised within the central administration — never before a State officer — even though it also covers State tax under sub-section (2)(a).
Statutory text as published on the CBIC tax information portal, as on 03.10.2026; the numbered notes record each amendment. Official source
Common questions
- Can both Central and State GST officers proceed against me for the same thing?
- Both may investigate. But once one has issued a show cause notice on a liability, section 6(2)(b) of the CGST Act bars the other from proceeding on the same liability on the same facts — Armour Security (SC, 2025).
- Is a GST summons the start of proceedings?
- No. In Armour Security (2025) the Supreme Court held that summons and searches are inquiry steps; proceedings for section 6(2)(b) begin with a show cause notice.
- Where does an appeal against a central officer's order lie?
- Within the central administration — section 6(3) bars rectification, appeal or revision of a central officer's order before a State officer.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
The State GST Acts contain the mirror provision, so a central officer is a proper officer for State tax too. This cross-empowerment, together with the administrative division of taxpayers between the Centre and the States agreed in the GST Council, gives each taxpayer a single administration for both taxes in ordinary matters, while either side may still act on intelligence.