M/S Armour Security (India) Ltd vs Commissioner, Cgst, Delhi East ...

The Supreme Court examined whether the issuance of summons under the CGST Act constitutes the 'initiation of proceedings' within the meaning of Section 6(2)(b). The court analyzed conflicting decisions of various High Courts and clarified the scope of 'proceedings' versus 'inquiry' or investigation. The judgment emphasizes the importance of understanding the procedural context and the empowerment of authorities under the law. Ultimately, the court provided guidance on the interpretation of procedural initiation in tax proceedings and upheld the legal framework governing summons issuance.