Delhi HC says Same GST Transactions Do Not Always Mean Same Subject Matter

Vertilink Media challenged a ₹10.58 crore GST demand on the ground that DGGI had already issued proceedings covering the same transactions. The Court held that the DGGI proceedings under Section 74 concerned fraudulent ITC without actual supply, while the later Section 73 proceedings concerned tax liability and ITC under Section 16(2)(c), and therefore were not the same subject matter.