Section 4 lets State and Union territory tax officers act as proper officers for IGST. With it, a taxpayer assigned to a State administration deals with one authority for CGST, SGST and IGST alike, instead of with the Centre for inter-State supplies.
Key points
- Under section 4 of the IGST Act, 2017, officers appointed under the State GST Acts and the UTGST Act are authorised to be proper officers for IGST, subject to exceptions and conditions notified on the GST Council's recommendation.
- Section 4 came into force on 01.07.2017.
- In Armour Security (India) Ltd v Commissioner, CGST (2025) the Supreme Court held that a summons is not the "initiation of proceedings" that bars a second authority under section 6(2)(b) of the CGST Act; the bar operates once a show cause notice has been issued on the same liability.
The provisions
4State and UT officers as proper officers for IGST
Statutory text
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 exceptions and conditions as the Government shall, on the recommendations of the Council, by notification, specify.
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. The Central GST authority then searched the company's premises under section 67 and summoned its directors under section 70. The company said the Central action was barred by section 6(2)(b) of the CGST Act, as the State had already initiated proceedings on the same subject matter.
- Held
- Appeal dismissed. A summons under section 70 is a step in inquiry or evidence-gathering, not the "initiation of any proceedings"; for section 6(2)(b) proceedings begin with a show cause notice. "Same subject matter" requires that both authorities pursue the same liability on the same facts and seek the same demand or relief; overlapping investigations alone do not meet it. The Court directed adherence to the CBIC guidelines on issuing summons and cautioned against routine summons.
- Here
- Cross-empowered State officers acting under section 4 and central officers under section 3 may both investigate; only one may adjudicate the same IGST liability.
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 a State GST officer act under the IGST Act?
- Yes. Section 4 of the IGST Act authorises State and UT tax officers to be proper officers for IGST, subject to notified exceptions and conditions.
- Can both Central and State officers proceed against me for the same IGST liability?
- Both may investigate, but once one has issued a show cause notice on a liability, section 6(2)(b) of the CGST Act (applied by section 20 IGST) bars the other from proceeding on the same subject matter — Armour Security (SC, 2025).
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
Without section 4, only central tax officers (section 3) could act under the IGST Act, and every taxpayer assigned to a State would need a central officer for its inter-State supplies. Section 4 removes that split: the State or UT officer becomes a proper officer for IGST "without prejudice" to the central officers' own powers.
The authorisation is "subject to such exceptions and conditions" as the Government notifies on the GST Council's recommendation. Read it with section 6 of the CGST Act, which applies to IGST through section 20: it cross-empowers Central and State officers, and section 6(2)(b) bars the second authority from initiating proceedings on a subject matter the first has already taken up.
Which taxpayer is administered by which side is an administrative allocation agreed in the GST Council, not something section 4 itself decides.