M/S Valtique Fintech Private Limited vs. Union Of INDIA
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The petitioner, M/s Valtique Fintech Private Limited, filed a writ petition before the Rajasthan High Court seeking to consolidate parallel investigations into the same subject matter being conducted by various Directorate General of GST Intelligence (DGGI) units. The petitioner sought directions to determine a single competent authority to conclude the investigation, citing the Supreme Court's judgment in M/s Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate. The petitioner argued that the DGGI Udaipur Regional Unit initiated the investigation first on September 15-16, 2025, and therefore, should be the sole authority to proceed. The respondents opposed this. The petitioner also offered to submit to the jurisdiction of CGST authorities in Delhi if the Rajasthan authorities were not agreeable. The High Court noted that the primary relief sought was against tax authorities based in Hyderabad.
Held
The Rajasthan High Court held that it did not deem it appropriate to entertain the writ petition. The Court reasoned that since the primary relief sought was against tax authorities based in Hyderabad, the petition should be filed before the High Court having territorial jurisdiction over those authorities. Therefore, the petition was disposed of with liberty to the petitioner to approach the concerned High Court. The Court acknowledged the reliance placed by both sides on the Supreme Court's judgment in M/s Armour Security (India) Ltd., particularly paragraph 97 concerning the determination of the competent authority for investigation. The Court did not delve into the merits of whether parallel proceedings were initiated or which authority should conduct the investigation, as it declined to entertain the petition on jurisdictional grounds. The Court also noted the petitioner's offer to submit to the jurisdiction of Delhi authorities and stated that such an offer, if made to the competent respondents, would be looked into in accordance with law.
Key Issues
1. Whether the Rajasthan High Court has territorial jurisdiction to entertain a writ petition seeking to consolidate investigations primarily involving tax authorities based in Hyderabad, even though the petitioner claims the earliest investigation was initiated within its territorial jurisdiction. Petitioner's Argument: The petitioner contended that the Rajasthan High Court has territorial jurisdiction because the earliest investigation was initiated by the DGGI Udaipur Regional Unit within its jurisdiction, and the subject matter of the investigation spans across the country. They relied on Section 6(2)(b) of the CGST Act, 2017, DGGI Guidelines, Board's Instructions, and the Supreme Court's decision in M/s Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate, which mandates that the authority first initiating an investigation should carry it to its logical conclusion if a decision on a single authority cannot be reached. Revenue's Argument: The respondents opposed the petitioner's contentions. The judgment does not explicitly detail the revenue's specific arguments regarding jurisdiction or the merits of the parallel investigations, other than their opposition to the petitioner's claims.
Sections Cited
Section 6(2)(b), Section 83, Rule 159
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
Order 25/09/2026
The petitioner is before us seeking the following reliefs: "i. Issue an appropriate writ, order or direction directing the Respondent No. 1-3, 4, 6 and 7to determine, in accordance with the principles laid down by the Hon'ble Supreme Court in M/s Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate & Anr2025 INSC 982, Section 6(2)(b) of the CGST Act, 2017 and the applicable DGGI Guidelines and Board's Instructions, the one competent authority/formation which shall proceed with and conclude the investigation concerning the Petitioner, and consequently direct cessation of all parallel investigations in respect of the same subject matter; and, in the event of failure to arrive at such determination, direct that the investigation proceed in the manner mandated by the aforesaid judgment of the Hon'ble Supreme Court; ii. Declare, in terms of paragraph 97 of M/s Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate & Anr., 2025 INSC 982, that in the absence of any inter se determination by the Respondents within a time-frame to be fixed by this Hon'ble Court, Respondent No. 4/5, being the authority whichfirst initiated the investigation on 15.09.2025 & 16.09.2025, shall alone be entitled to continue and carry the investigation to its logical conclusion, and consequently direct Respondent Nos. 6 and 7 to forthwith cease all further investigation, proceedings and coercive action against the Petitioner in respect of the said subject matter and to transmit all material, statements, documents and records gathered by them to Respondent No. 4/5; iii. Issue an appropriate writ, order or direction declaring the parallel investigations/proceedings being simultaneously conducted by Respondent Nos. 6 & 7 against the Petitioner, in respect of the same subject matter, as illegal, arbitrary and contrary to the provisions of the CGST Act, 2017, including Section 6(2)(b) , and the applicable DGGI Guidelines and Board's Instructions dated 30.03.2024, and the binding directions of the Hon'ble Supreme Court in M/s Armour Security (India) Ltd. v. Commissioner, CGST, Delhi East Commissionerate & Anr., 2025 INSC 982; iv. Issue an appropriate writ, order or direction quashing and setting aside the investigation, search and seizure proceedings undertaken by Respondent Nos. 6 & 7 against the Petitioner in respect of the aforesaid subject matter, and all consequential proceedings arising therefrom including the summons dated 20.07.2026, 31.07.2026, 17.08.2026 and 25.08.2026; v. Issue an appropriate writ, order or direction quashing and setting aside FORM GST DRC-22 dated 13.08.2026 issued by Respondent No. 7 under Section 83 of the CGST Act, 2017, being
[2026:RJ-JP:39040-DB] (3 of 4) [CW-18337/2026] issued in furtherance of a parallel investigation concerning the same subject matter already under investigation by Respondente No. 4/5 and without compliance with the requirements of Section 83 read with Rule 159 of the CGST Rules, 2017; and consequently direct release and de-freezing of the bank accounts of the Petitioner covered thereunder; vi. Direct Respondent Nos. 6 and 7 to return to the Petitioner all documents, records, computers, laptops and mobile phones seized during the searches conducted by them, including the. articles seized vide FORM GST INS-02 dated 12.08.2026 by Respondent No. 7, subject to such conditions as this Hon'ble Court may deem fit; vii. Pass such other and further order(s) as this Hon'ble Court may deem fit and proper in the facts and circumstances of the present case, in the interests of justice."
It transpires from the memo of parties that the relief is essentially directed against the officers of the CGST, at Hyderabad. Though, of course, the earliest proceedings, which the petitioner claims to be based on the same cause of action and similar facts, were initiated in Rajasthan, i.e. within the territorial juri iction of this Court, thus the instant petition is preferred before this Court.
Whether or not parallel proceedings have been initiated on the same cause of action or similar facts ultimately will have to be adjudicated upon by the Court having territorial juri iction. Since the relief sought is against the tax authorities based in Hyderabad, we do not deem it appropriate to entertain the instant petition. The same is accordingly disposed of with liberty to the petitioner to approach the concerned High Court.
In the parting, we may also like to observe that during the course of arguments, both the sides rather emphatically relied upon the judgment rendered by Hon'ble The Supreme Court in the case of M/S thereof, which reads as under:- "g. However, where the authorities are unable to reach a decision as to which of them shall continue with the inquiry or investigation, then 1 2025 INSC 982
[2026:RJ-JP:39040-DB] (4 of 4) [CW-18337/2026] in such circumstances, the authority that first initiated the inquiry or investigation shall be empowered to carry it to its logical conclusion, and the courts in such a case would be competent to pass an order for transferring the inquiry or investigation to that authority."
Apropos, learned senior counsel appearing for the petitioner would submit that, though as per the aforesaid guideline, the competent authority in Rajasthan, being the first to initiate the inquiry/investigation, which ought to and is empowered to carry out the further proceedings under the CGST Act to their logical conclusion.
However, learned senior counsel appearing for the respondents would oppose the same.
Confronted with the aforesaid, learned senior counsel for the petitioner would submit that, in case the respondents are not agreeable to Rajasthan, the petitioner has no objection and would be willing to submit to the juri iction of the Central Government tax authorities at Delhi, where also subsequent parallel proceedings have been initiated based on same cause and same facts, since the company is also registered and located at Delhi and all the records pertaining to the transactions, which span across the country, are being maintained at Delhi.
We do not wish to dilate on the aforesaid submissions and suffice for us to observe, in the parting, that in case the petitioner approaches the competent authority respondents with such an offer, the same shall be looked into in accordance with law and in case any indulgence is warranted, needful action shall be taken within a period of two weeks.
All pending applications stands disposed of. (ASHUTOSH KUMAR),J (ARUN MONGA),J 53/Ashwani-Tanisha
Reproduced from the public record of the Rajasthan High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.