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'Appeals in DGGI-led multi-state cases must be filed where CAA is posted'
The Central Board of Indirect Taxes and Customs (CBIC) has clarified that appeals against orders passed by Common Adjudicating Authorities (CAAs) in multi-state GST investigations by the Directorate General of GST Intelligence (DGGI) must be filed in the jurisdiction where the CAA is posted.
The clarification, issued through a circular dated 24 June, addresses a key procedural gap in the earlier December 2024 circular, which had designated CAAs for adjudicating show-cause notices issued by DGGI but did not specify where appeals, reviews or revisions of such orders should be filed.
'This had led to confusion in cases where investigations were conducted across multiple states. For example, if the DGGI investigated a company in Mumbai, Kolkata and New Delhi, and the CAA was posted in New Delhi, it was unclear whether the appeal should be filed in Maharashtra, West Bengal or Delhi,' said Vivek Jalan, partner, Tax Connect Advisory Services.
The new circular brings clarity by stating that all legal follow-up actions — including appeals, reviews and revisions — must be carried out within the jurisdiction of the Commissioner or Principal Commissioner under whom the CAA functions. Appeals will lie with the Commissioner (Appeals) of the same jurisdiction, and the department's representation will also come from that Commissionerate.
Further, the reviewing or revisional authority may seek inputs from the relevant DGGI formation before deciding on the order. The clarification is aimed at ensuring consistency and avoiding jurisdictional disputes in DGGI-led proceedings where a CAA has been appointed. Field officers have been instructed to issue trade notices to disseminate the circular, and any challenges in its implementation are to be reported to the Board.
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