Multiple GST Orders for Same Financial Year: Jurisdiction, Duplication and Remedies

Summary: Multiple GST notices and adjudication orders against the same GSTIN for one financial year are not automatically unlawful. The decisive questions are whether the proceedings concern independent transactions and liabilities, whether each officer holds a valid assignment and whether an invoice or tax demand has already been covered by an earlier notice or order. In Armour Security (India) Ltd., the Supreme Court clarified that the same taxpayer or tax period does not necessarily amount to the same subject matter for Section 6(2)(b); the particular contravention and liability must be compared. That provision principally addresses Central–State proceedings and cannot automatically be extended to every allocation between officers of the same State administration. For FY 2023–24, Sections 73 and 74 remain relevant, whereas Section 74A applies from FY 2024–25. A Karnataka High Court decision concerning two Section 73 orders by different officers illustrates the need to examine overlapping adjudication carefully, although its precise scope must be checked against the judgment. Taxpayers should maintain a consolidated register of notices, assignments, invoices, amounts and prior orders, respond to every outstanding notice, request a personal hearing and seek coordination from the JCCT (Administration). Each completed order must be assessed separately for limitation and appeal under Section 107, including the prescribed pre-deposit; an administrative representation does not suspend appellate deadlines. The objection should establish duplication invoice by invoice rather than depend on a broad assertion that only one order can exist for one year.

One Taxpayer, One Financial Year, Several GST Orders: Where Does Lawful Adjudication End and Duplication Begin?

1. The practical difficulty faced by the taxpayer

A taxable person receives an adjudication order for FY 2023–24 from one officer. Thereafter, another officer in the same region passes another order for the same year. Meanwhile, three or four other officers have issued show cause notices concerning transactions with different buyers.

When questioned, each officer refers to the assignment made by the Joint Commissioner of Commercial Taxes (Administration).

The taxpayer is then left with several proceedings, several hearings, several demands and, potentially, several appeals. The difficulty becomes more serious when the officers do not appear to have a common record of the notices issued and orders already passed.

The concern is genuine. However, the legal objection must be framed carefully.

The strongest objection is not merely that “another order has already been passed for this financial year”. It is that the later proceeding lacks lawful assignment, overlaps an existing proceeding, repeats a demand already determined, or fails to consider the earlier adjudication. The distinction between a separate liability and a repeated liability is central to the issue.

This article examines the position where several notices or orders are issued against the same GSTIN. Orders issued separately against different buyers under their own GSTINs stand on a different footing; they are not, merely for that reason, multiple orders against the supplier.

2. Does GST law permit only one order for one financial year?

An objection based solely on the proposition “one financial year, one adjudication order” is unsafe.

For example, one proceeding may concern short-payment of output tax on supplies to Buyer A. Another may concern an unrelated reverse-charge liability. A third may concern an entirely different input-tax-credit transaction.

The fact that all three relate to FY 2023–24 does not, by itself, make them the same subject matter. The Supreme Court’s analysis in Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate & Anr., 2025 INSC 982, requires examination of the particular liability, contravention and demand—not merely the taxpayer’s name or financial year.

For FY 2023–24, the relevant demand provisions remain Sections 73 and 74, depending upon the allegations and statutory conditions. Section 74A governs FY 2024–25 onwards; the date on which an officer now issues the notice does not, by itself, shift an FY 2023–24 dispute into Section 74A.

The real issue, therefore, is duplication.

Situation	Position to be examined
Same GSTIN and same year, but genuinely different transactions and liabilities	Multiple proceedings are not automatically barred merely because the year is common.
Same invoices and same alleged short-payment included in two demands	A substantial objection arises against repeated determination of the same liability.
One proceeding covers the entire annual mismatch; another covers invoices already included in that mismatch	The overlapping portion must be identified and specifically challenged.
Different buyers are mentioned, but all notices arise from one common alleged default	Examine the actual scope of each notice; different buyer names alone do not resolve the issue.
Orders are against different buyers under different GSTINs	These are proceedings against separate taxable persons, although findings may have consequences for the supplier.

The governing comparison is between the facts, transactions, alleged contravention and relief or demand sought in each proceeding.

3. Different buyers do not, by themselves, justify different demands

The expression “different buyers” requires particular attention.

Suppose a supplier has made sales to six buyers. The Department receives information from the officers administering those buyers and forwards six references for action against the supplier.

The existence of six references does not establish six independent tax liabilities. Equally, it does not establish that all six proceedings are duplicates.

The notices must answer:

• Which invoices are involved?
• What default is alleged against the supplier?
• Is the demand for unpaid output tax, reversal of ITC, or a penalty?
• Has the same transaction already been included in another notice or order?
• Is the allegation confined to that buyer, or does it form part of a wider annual demand?

This is the practical application of the Supreme Court’s transaction-and-liability-based approach. A change in the source of departmental information does not necessarily change the subject matter of adjudication.

A practitioner should also keep the persons and liabilities distinct. A buyer’s ITC dispute and a supplier’s output-tax dispute cannot be treated as identical merely because both arise from the same invoice. The proposed liability against each person must first be identified.

4. What is the effect of assignment by the JCCT (Administration)?

An assignment order is relevant to jurisdiction. It is not a complete answer to an allegation of overlapping adjudication.

The proper questions are:

• What statutory function was assigned?
• Who had authority to make that assignment?
• Which GSTIN, financial year and subject matter does it cover?
• Does it authorise investigation, issuance of notice, adjudication, or more than one of these functions?
• Are there applicable territorial or monetary restrictions?
• Has another officer already been assigned the same matter?

The concept of “proper officer” under Section 2(91), read with the applicable provisions on powers and delegation, makes assignment of the particular function important. The actual Karnataka orders applicable to the officer and the case must be examined; the officer’s designation or presence in the same region is not, by itself, conclusive.

Accordingly, the taxpayer should request copies or particulars of:

• The case-specific JCCT assignment.
• The notification, delegation or authorisation supporting that assignment.
• Any subsequent transfer, modification or reassignment.
• The precise scope of the proceeding entrusted to each officer.

Without examining these documents, it would be premature either to declare all the officers competent or to declare all their proceedings without jurisdiction.

5. Section 6(2)(b): an important safeguard, but not a universal answer

Section 6(2)(b) addresses the initiation of proceedings on the same subject matter by the Central and State GST administrations.

In Armour Security, decided on 14 August 2025, the Supreme Court explained, among other things, that:

• Summons or investigation do not, by themselves, constitute initiation of adjudicatory proceedings for this purpose.
• The show cause notice crystallises the alleged contravention and proposed liability.
• The same taxpayer or the same tax period does not necessarily mean the same subject matter.
• Identical or overlapping liability arising from the particular contravention requires scrutiny under the statutory bar.
• Distinct infractions are not converted into the same subject matter merely because the resulting tax amounts appear similar.

An important limitation must be recognised in the present Karnataka situation.

Where all the officers belong to the Karnataka State Commercial Taxes Department, Section 6(2)(b) should not be cited mechanically as though it expressly regulates every allocation between two State officers. Its immediate statutory context concerns the Central–State interface. For proceedings within the State Department, the objection must also rest on the applicable assignment orders, the actual overlap, the earlier adjudication and procedural fairness.

This distinction makes the representation more precise and avoids resting the entire case on a provision whose direct application may be disputed.

6. A relevant Karnataka High Court decision

A reported Karnataka decision directly deserves examination: M/s Nagana Contractor, W.P. No. 36301 of 2025 (T-RES), decided on 18 December 2025, neutral citation 2025: KHC:54222.

According to the available report:

• Two officers had passed orders under Section 73(9) for FY 2019–20.
• The orders were dated 20 July 2024 and 12 August 2024.
• The High Court set aside both orders and remitted the matter for fresh consideration before one authority, permitting the taxpayer to file its reply and documents and receive a personal hearing.

This is a useful Karnataka authority for investigating and challenging duplicate adjudication by different officers.

However, a necessary professional caution applies: the source available for this research is a secondary report, not the authenticated judgment. The signed order should be obtained and its facts examined before quoting it in an appeal or writ petition. The report should not be enlarged into an unrestricted proposition that every second order for a financial year is void, irrespective of its subject matter.

7. Illustrations

The following illustrations are hypothetical. They show how the same-year issue should be examined in practice.

Illustration 1: Separate buyers and separate omitted supplies

M/s Karnataka Traders has allegedly omitted:

• Supplies to Buyer A involving tax of ₹1,80,000.
• Separate supplies to Buyer B involving tax of ₹90,000.

Officer A proceeds only on Buyer A’s invoices. Officer B proceeds only on Buyer B’s invoices. Neither demand includes the other’s transactions.

Here, an objection based only on the common FY 2023–24 is insufficient. The practitioner must separately examine jurisdiction, evidence, tax computation and procedure. Administrative consolidation may be requested, but it should not be presented as an automatic statutory entitlement merely because the year is the same.

Illustration 2: The same invoice demanded twice

Officer A confirms tax of ₹1,80,000 on Invoice No. 125 issued to Buyer A.

Officer B subsequently includes the same invoice and the same alleged unpaid tax in another demand against the same supplier.

This is not simply a case of “two orders in one year”. It is a case of the same liability being determined twice. The objection should identify the invoice, tax head, tax period, allegation and amount appearing in both proceedings. Where the officers belong to different administrations, Section 6(2)(b) must also be examined.

Illustration 3: Annual mismatch followed by buyer-wise demands

Officer A passes an order confirming an annual outward-tax mismatch of ₹10 lakh.

Later:

• Officer B demands ₹2 lakh relating to Buyer B.
• Officer C proposes ₹1.5 lakh relating to Buyer C.

If the ₹2 lakh and ₹1.5 lakh are already components of the ₹10 lakh determined by Officer A, the taxpayer must demonstrate that overlap through reconciliation.

It is not enough to produce only the earlier order’s first page. The annexures and working sheets may be decisive in showing whether the later amounts were included. This follows from the requirement to compare the actual liability and factual basis of the proceedings.

Illustration 4: Same year, unrelated issues

Officer A determines unpaid tax on particular outward supplies.

Officer B examines ITC on an unrelated set of purchase invoices.

The proceedings concern the same taxpayer and year but may involve distinct liabilities and infractions. The first order does not necessarily provide immunity from the second proceeding.

8. What should the taxpayer do when further DRC-01 notices are pending?

Prepare one consolidated proceeding register

The taxpayer should first bring the entire record into one statement:

Particulars	Information to record
Taxpayer	Legal name and GSTIN
Authority	Officer’s name, designation and office
Assignment	Number, date and stated scope
Notice	SCN reference, date and DRC-01 reference
Period	Financial year and relevant months
Counterparty	Buyer or supplier name and GSTIN
Transactions	Invoice numbers, dates and values
Allegation	Exact default alleged
Amount	Tax, interest and penalty separately
Earlier coverage	Other SCN/order containing the same transaction
Present stage	Reply pending, hearing fixed, order passed or appeal filed
Deadline	Reply date or appeal limitation

The purpose is not merely record-keeping. It is to establish, with documents, whether the demands are independent, partly overlapping or wholly repetitive.

Reply to every pending notice

Do not leave a notice unanswered merely because another officer has already passed an order.

In each reply:

• Raise the jurisdiction and overlap objections expressly.
• Attach the consolidated statement.
• Identify the exact overlapping invoices and amounts.
• Furnish the earlier notices, orders and relevant annexures.
• Answer the merits without prejudice to those objections.
• Request a personal hearing.
• Ask for a reasoned finding on jurisdiction and duplication before any adverse determination.

Section 75(4) requires a hearing where requested in writing or where an adverse decision is contemplated. Section 75(6) requires the order to state the relevant facts and the basis of the decision. Section 75(7) restricts the order to the amount and grounds contained in the notice.

Submit a consolidated representation to the JCCT

The representation should seek:

• Verification of every assignment against the GSTIN for FY 2023–24.
• Identification and removal of overlapping subject matter.
• Circulation of earlier notices and orders to all concerned officers.
• A clear written allocation of the matters that remain pending.
• Assignment of connected pending matters to one competent adjudicating authority, where legally permissible.
• Appropriate directions to prevent repeated determination or recovery of the same liability.

This should be framed as a request for lawful coordination, not as a demand that the JCCT informally cancel final adjudication orders. Orders already passed require the appropriate statutory or judicial remedy.

9. What should be done about the orders already passed?

Protect each appeal independently

For each order, ascertain its date of communication and calculate limitation separately.

Section 107 ordinarily provides:

• Three months to appeal from communication of the order.
• A further one month that may be condoned on sufficient cause.
• Payment of admitted dues and the prescribed pre-deposit—ordinarily 10% of disputed tax for a tax-demand appeal, subject to the applicable statutory ceiling.
• Deemed stay of recovery of the balance upon compliance with Section 107(6).

Where there are separate orders, do not assume that challenging one order protects the others.

A representation to the JCCT is not an appeal and should not be treated as suspending appeal limitation.

Consider a writ where the jurisdictional defect is demonstrable

A writ petition may be considered where the record clearly establishes duplicate adjudication, absence of lawful jurisdiction or a serious procedural defect. However, the taxpayer should not assume that merely alleging these grounds guarantees High Court interference.

Where identity of subject matter is not established and the dispute requires factual examination, the statutory appeal may remain the appropriate remedy. A recent Delhi High Court decision applying Armour Security rejected the asserted parallel-proceedings bar and relegated the taxpayer to Section 107.

For client, the choice between appeal and writ should therefore be made after comparing the actual SCNs, their annexures, the assignment orders and the adjudication findings—not merely by counting the number of orders.

10. Suggested preliminary objection for pending proceedings

The following paragraph may be adapted after inserting the actual references:

The taxable person submits that proceedings concerning FY 2023–24 have been initiated and, in certain instances, concluded by different officers of the Commercial Taxes Department. A consolidated statement of the notices, assignment particulars, adjudication orders and invoice-wise coverage is enclosed.

The present objection is not founded merely on the financial year being common. It concerns the extent to which the transactions and proposed liability covered by the present notice have already been included in another pending proceeding or adjudication order.

The overlap identified in Annexure _ may kindly be verified against the records of the concerned officers. The taxable person requests disclosure of the assignment and authorisation under which the present proceedings are being conducted, a reasoned determination of the jurisdictional and duplication objections, and suitable administrative coordination through the JCCT (Administration).

No liability already determined in another proceeding should be determined or recovered again without addressing the earlier adjudication and the objections now placed on record. An opportunity of personal hearing under Section 75(4) is requested. The submissions on merits are furnished without prejudice to these preliminary objections.

The facts concerning overlap must be completed accurately; the paragraph should not be used to assert duplication where the invoice comparison does not support it.

11. What administrative measure is required in Karnataka?

The situation described calls for a GSTIN-wise proceeding register accessible to officers making assignments and officers conducting adjudication.

A practical departmental protocol could require:

• Checking existing proceedings before issuing a fresh assignment.
• Recording the GSTIN, period, issue and invoice coverage in every assignment.
• Flagging overlap with pending notices and completed orders.
• Identifying a coordinating authority for connected cases.
• Requiring every adjudication order to address disclosed earlier proceedings.
• Preventing duplicate demand entries and recovery action.

These are suggested administrative safeguards, not a statement that such a specific statewide protocol is already mandated by a verified Karnataka circular.

The reported Nagana Contractor matter shows that disputes over two officers’ orders for the same period have reached the Karnataka High Court. It does not, by itself, establish the extent of the problem throughout Karnataka. A professional association’s representation would be stronger if supported by anonymised case schedules showing the assignments, overlapping invoices, repeated demands and additional appeal burden.

Conclusion

A taxpayer cannot claim that the first adjudication order for FY 2023–24 closes every possible GST issue for that year. At the same time, the Department cannot answer a demonstrated case of duplicate adjudication merely by stating that different officers received different assignments.

The correct approach is to identify the liability covered by each proceeding, verify the authority of each officer, and establish any repetition invoice by invoice. That approach is consistent with the Supreme Court’s distinction between a common financial year and the same subject matter.

For the client described, the immediate priority is clear: file protective appeals against the existing orders within time, submit detailed replies to the pending notices, and place a consolidated overlap statement before the JCCT (Administration). If the documents establish repeated adjudication of the same liability, the challenge should be directed at that specific defect, supported by the assignments, notices, annexures and earlier orders.

Administrative division of work should assist proper adjudication. It should not leave the taxable person to discover, after several orders are passed, that the same transaction has travelled through several departmental files.