Case Title: Haigreeva Infratech Projects Ltd vs State of Andhra Pradesh and Others
Court: High Court of Andhra Pradesh, Amaravati
Petition No.: W.P. No. 16976 of 2024
Date of Judgment: 19 February 2025
Category: Jurisdiction – Dual Assessment under GST
Relevant Sections: Section 6 of the CGST Act and APGST Act (assessment by one authority only)
Facts (Para 1–3)
Haigreeva Infratech Projects Ltd was served with assessment notices by both the State GST Authorities and the Directorate General of GST Intelligence (DGGI) for the period 2017–2021. Aggrieved by the simultaneous proceedings, the petitioner contended that under Section 6 of the CGST and APGST Acts, only one authority—either State or Central—can conduct an assessment for a particular transaction or period, and dual proceedings violate the principle of single jurisdiction under GST.
Questions of Law
Whether both State GST and Central GST Authorities can initiate parallel assessment proceedings for the same taxpayer and tax period.
Court’s Observations (Para 5–6)
The Government Pleader informed the Court that the Central Authority (2nd respondent) had withdrawn its proceedings, and that the State Authority (3rd respondent) had already completed the assessment. As there was no longer any subsisting dispute of jurisdiction, the Court held that the writ petition had become infructuous.
Judgment (Para 6)
The Court dismissed the writ petition as infructuous since the overlapping assessment was resolved. No costs were awarded. All connected miscellaneous petitions were closed.
Summary of Referred or Related Cases
| Case | Court | Issue | Outcome |
|---|---|---|---|
| Haigreeva Infratech Projects Ltd v. State of Andhra Pradesh | AP High Court | Dual assessment by State and Central GST | Dismissed as infructuous after one authority withdrew |
Between Fine Lines (Practical Takeaway)
This case underscores that simultaneous assessments by both State and Central GST authorities for the same period are not permissible. Once one authority exercises jurisdiction, the other must abstain. For taxpayers, it reinforces the need to promptly challenge dual notices and seek clarification of jurisdiction under Section 6 of the CGST and State GST Acts to avoid conflicting demands.
Disclaimer – “The above summary is for academic purpose only; not formal legal opinion. Seek professional opinion before application. Author or publisher or website shall not be responsible for any usage in any form.”
