Under GST both the Central and State tax departments have powers over every taxpayer, but for routine administration each GSTIN is assigned to one of them. The assignment was decided by the GST Council and is done by the system, not chosen by the taxpayer.
The GST Council decided early on how to divide taxpayers within each State. Of taxpayers with turnover below Rs. 1.5 crore, 90 percent are administered by the State and 10 percent by the Centre. Of those with turnover of Rs. 1.5 crore and above, the split is equal. Within these groups, allocation is done by computer through stratified random sampling, broadly reflecting geography and type of taxpayer.
That is why two similar shops on the same street can be administered by different departments.
Section 6 of the CGST Act makes State officers proper officers for Central tax and vice versa, subject to conditions. So enforcement actions, such as inspections, audits by special wings or intelligence-based investigations, can come from the department that does not administer you.
Section 6(2)(b) provides that where one authority has initiated proceedings on a subject matter, the other shall not initiate proceedings on the same subject matter. If you receive two notices on the same issue for the same period from both sides, point this out in your replies with copies of both notices.
Check your administering office on the portal before writing letters or visiting. Reply to every notice to the officer who issued it, even if that officer is not your administering authority. A professional can track notices from both sides and flag any overlap.
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This guide explains the law in general terms as of October 2026. Time limits and requirements can depend on the facts of your case and on the notice you received.
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