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Circular No. 239/33/2024-GST
F. No. CBIC-20016/2/2022-GST
Government of India
Ministry of Finance
(Department of Revenue)
Central Board of Indirect Taxes & Customs
GST Policy Wing
*****
New Delhi, dated the 4
th
December, 2024
To,
The Principal Chief Commissioners/ Chief Commissioners (All)
The Principal Directors General/ Directors General (All)
Madam/Sir,
Subject: Amendment to Circular No. 31/05/2018-GST, dated 9th February, 2018 on
'Proper officer under sections 73 and 74 of the Central Goods and Services Tax Act, 2017
and under the Integrated Goods and Services Tax Act, 2017'–reg.
Vide Notification No. 02/2022-Central Tax dated 11
th
March, 2022, para 3A was
inserted in Notification No. 02/2017-Central Tax dated 19
th
June, 2017, to empower Additional
Commissioners of Central Tax/ Joint Commissioners of Central Tax of some of the specified
Central Tax Commissionerates, with All India Jurisdiction for the purpose of adjudication of
the show cause notices issued by the officers of the Directorate General of Goods and Services
Tax Intelligence (herein after referred as DGGI). Further, vide Notification No. 27/2024-
Central Tax dated 25
th
November, 2024, Table V has been substituted in the Notification No.
02/2017-Central Tax dated 19th June, 2017, to empower more number of Additional
Commissioners of Central Tax/ Joint Commissioners of Central Tax of specified Central Tax
Commissionerates, with All India Jurisdiction for the purpose of adjudication of the show cause
notices issued by the officers of DGGI. Notification No 27/2024- Central Tax dated 25
th
November, 2024 has come into effect from 1
st
December, 2024.
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2. Consequently, para 7.1 of the Circular No. 31/05/2018-GST dated 9
th
February, 2018
(as amended by Circular No. 169/01/2022-GST dated 12
th
March, 2022) is substituted as
below:
“7.1 In respect of show cause notices issued by officers of DGGI, there may
be cases where,
(i) a show cause notice is issued to multiple noticees, either having the same
or different PANs; or
(ii) multiple show cause notices are issued on the same issue to multiple
noticees having the same PAN,
and the principal place of business of such noticees fall under the jurisdiction
of multiple Central Tax Commissionerates. For the purpose of adjudication of such
show cause notices, Additional/Joint Commissioners of Central Tax of specified
Commissionerates have been empowered with All India jurisdiction through
amendment in the Notification No. 02/2027 dated 19
th
June, 2017 vide Notification No.
02/2022-Central Tax dated 11
th
March, 2022, as further amended vide Notification No.
27/2024-Central Tax dated 25
th
November, 2024. Such show cause notices may be
adjudicated, irrespective of the amount involved in the show cause notice(s), by one of
the Additional/Joint Commissioners of Central Tax empowered with All India
jurisdiction vide the above mentioned notifications. Principal Commissioners/
Commissioners of the Central Tax Commissionerates specified in the said notification
will allocate charge of Adjudication (DGGI cases) to one or more Additional
Commissioners/ Joint Commissioners posted in their Commissionerates. Where the
location of principal place of business of the noticee, having the highest amount of
demand of tax in the said show cause notice(s), falls under the jurisdiction of a Central
Tax Zone/Commissionerate mentioned in column 2 of the table below, the show cause
notice(s) may be adjudicated by one of the Additional Commissioners/ Joint
Commissioners of Central Tax, holding the charge of Adjudication (DGGI cases), of
the Central Tax Commissionerate mentioned in column 3 of the said table
corresponding to the said Central Tax Zone/Commissionerate. Such show cause
notice(s) may, accordingly, be made answerable by the officers of DGGI to the
concerned Additional/ Joint Commissioners of Central Tax.
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TABLE
7.1.1 It is further clarified that in cases where a show cause notice has been issued
to multiple noticees, either having same or different PANs, and the said show cause
Sl. No. Central Tax Zone/ Commissionerates in
whose jurisdiction the location of the
principal place of business of the noticee
having highest amount of demand of tax
involved falls
Central Tax Commissionerate
whose Additional Commissioner or
Joint Commissioner shall adjudicate
Show Cause Notices issued by
officers of Directorate General of
GST Intelligence
(1) (2) (3)
1. Ahmedabad Zone Ahmedabad South
2. Vadodara Zone Surat
3. Bhopal Zone Bhopal
4. Nagpur Zone Nagpur-II
5. Chandigarh Zone Chandigarh
6. Panchkula Zone Faridabad
7. Chennai Zone Chennai South
8. Bengaluru Zone Bengaluru East
9. Thiruvananthapuram Zone Thiruvananthapuram
10. Delhi North and Delhi East
Commissionerates of Delhi Zone
Delhi North
11. Delhi West and Delhi South
Commissionerates of Delhi Zone
Delhi West
12. Jaipur Zone Jaipur
13. Guwahati Zone Guwahati
14. Hyderabad Zone Rangareddy
15. Visakhapatnam (Amaravathi) Zone Visakhapatnam
16. Bhubaneshwar Zone Bhubaneshwar
17. Kolkata Zone Kolkata North
18. Ranchi Zone Ranchi
19. Lucknow Zone Lucknow
20. Meerut Zone Meerut
21. Mumbai West, Thane, Thane Rural, Raigarh,
Belapur, Navi Mumbai and Bhiwandi
Commissionerates of Mumbai Zone
Thane
22. Mumbai South, Mumbai East, Mumbai
Central and Palghar Commissionerates of
Mumbai Zone
Palghar
23. Pune Zone Pune-II
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notice is required to be adjudicated by a common adjudicating authority as per the
highest amount of demand of tax in accordance with the criteria mentioned in para 7.1
above, then if any show cause notice(s) is issued subsequently on the same issue to some
other noticee(s) having PAN(s) different from the PANs of the noticees included in the
earlier show cause notice, the said later show cause notices is to be adjudicated,
(i) by the jurisdictional adjudicating authority of the noticee, if there is only one
noticee (GSTIN) involved in the said later show cause notice; or
(ii) by the common adjudicating authority in accordance with the criteria
mentioned in para 7.1 above as applicable independently based on the highest
amount of tax demand in the said later show cause notice, if there are multiple
noticees (GSTINs) involved in the said later show cause notice having principal
place of business under the jurisdiction of multiple Central Tax
Commissionerates.’’
3. Further para 7.3 of the Circular No. 31/05/2018-GST dated 9
th
February, 2018 (as
amended by Circular No. 169/01/2022-GST dated 12
th
March, 2022) is substituted as below:
“7.3 In respect of show cause notices issued by the officers of DGGI prior to
Notification No. 27/2024-Central Tax dated 25
th
November, 2024 coming into effect,
involving cases mentioned in para 7.1 read with para 7.1.1 above and where no
adjudication order has been issued upto 30
th
November, 2024, the same may be made
answerable to the Additional/Joint Commissioners of Central Tax, having All India
jurisdiction, in accordance with the criteria mentioned in para 7.1 read with para 7.1.1
above, by issuing corrigendum to such show cause notices.”
4. It is requested that suitable trade notices may be issued to publicize the contents of this
circular.
5. Difficulty, if any, in implementation of the above instructions may please be brought to
the notice of the Board. Hindi version would follow.
(Sanjay Mangal)
Principal Commissioner (GST)
