The Rajasthan High Court has declined to entertain a company’s petition challenging alleged parallel GST investigations and the provisional attachment of its bank accounts, observing that the relief was essentially directed against tax authorities based in Hyderabad.

The Bench of Justice Arun Monga and Justice Ashutosh Kumar has disposed of the petition with liberty to approach the concerned High Court.

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The company had sought consolidation of investigations being conducted by different formations of the Directorate General of GST Intelligence (DGGI), alongside relief against summons, searches, seizures and bank account attachment.

The company contended that different DGGI formations were investigating the same subject matter. It sought a direction requiring the authorities to identify one competent formation to continue and conclude the investigation, with the other formations ceasing their parallel proceedings.

According to the company’s pleadings, the earliest investigation had commenced in Rajasthan on September 15 and 16, 2025. It argued that the Rajasthan authorities should therefore carry the investigation to its logical conclusion if the authorities could not agree among themselves on which formation should proceed.

The company relied on Section 6(2)(b) of the Central Goods and Services Tax Act, 2017, applicable DGGI guidelines, Board instructions and the Supreme Court’s decision in M/s Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate & Anr., 2025 INSC 982.

It also sought directions requiring the Mumbai and Hyderabad formations to transmit the material, statements, documents and records collected by them to the Rajasthan formation.

The petition sought the quashing of investigation, search and seizure proceedings undertaken by the Mumbai and Hyderabad formations, including summons dated July 20, July 31, August 17 and August 25, 2026.

The company also challenged a provisional attachment order issued by the Hyderabad formation in Form GST DRC-22 on August 13, 2026, under Section 83 of the CGST Act. It sought the release and de-freezing of the bank accounts covered by that order.

Its case was that the attachment arose from an investigation into a subject already being examined by the Rajasthan authorities and did not comply with Section 83 read with Rule 159 of the CGST Rules, 2017.

The company further sought the return of documents, records, computers, laptops and mobile phones seized during searches, including articles covered by Form GST INS-02 dated August 12, 2026.

These were the company’s allegations and requests for relief; the High Court did not adjudicate their merits.

The Bench noted that the company had approached it because the earliest proceedings, allegedly involving the same cause of action and similar facts, had commenced within Rajasthan.

However, after examining the parties and the relief sought, the court observed that the petition was essentially directed against CGST officers at Hyderabad.

It held that the question of whether parallel proceedings had been initiated on the same cause of action or similar facts would have to be adjudicated by the court having territorial jurisdiction. Since the relief was sought against authorities based in Hyderabad, the Bench considered it inappropriate to entertain the petition.

The petition was accordingly disposed of with liberty to approach the concerned High Court. The Bench did not quash the investigations, summons or attachment order, or direct the de-freezing of the company’s bank accounts.

As reproduced in the order, the guideline provides that where authorities cannot agree on which of them should continue an inquiry or investigation, the authority that initiated it first is empowered to take it to its logical conclusion. Courts may, in such circumstances, order the transfer of the inquiry or investigation to that authority.

The company argued that this principle supported continuation of the investigation by the Rajasthan formation. Counsel for the respondents opposed that submission.

The High Court did not resolve the competing arguments or order a transfer of the investigation.

The company’s senior counsel alternatively submitted that, if the respondents were unwilling to agree to Rajasthan, the company was willing to submit to the jurisdiction of the Central Government tax authorities at Delhi.

Counsel stated that subsequent parallel proceedings had also commenced in Delhi on the same cause and facts. The company was registered and located there, and the records relating to its transactions across the country were maintained in Delhi.

The Bench observed that if the company approached the competent respondent authorities with such an offer, it should be examined in accordance with law. If any indulgence was warranted, the necessary action was to be taken within two weeks.

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