The Delhi High Court has dismissed a writ petition challenging a Rs. 10.57 crore demand raised by the Delhi State Tax Officer under Section 73 on the ground that the DGGI had earlier issued a Section 74 SCN covering the same period, holding that the two proceedings concerned different subject matter and the bar under Section 6(2)(b) was not attracted. The ruling by Justice Anil Kshetarpal and Justice Rajneesh Kumar Gupta in WP(C) 13077/2026 (M/s Vertilink Media Solutions, decided 25.09.2026) further held that the subsequent conclusion of the DGGI proceedings (where the principal noticee M/s Zee Entertainment paid the entire demand and co-noticees’ proceedings were deemed concluded under Explanation 1 to Section 74) cannot retroactively invalidate independently initiated State proceedings. The Section 73 notice concerned non-declaration of correct tax liability and ITC admissibility under Section 16(2)(c); the DGGI Section 74 SCN alleged fraudulent ITC without actual supply of goods against 45 noticees — materially different statutory provisions, allegations and liability. The court also rejected the petitioner’s reliance on Section 75(13) (no penalty for same act or omission), as no penalty had actually been imposed on the petitioner in the DGGI proceedings.