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The AT held that the Respondent engaged in profiteering under Section 171, CGST Act, by failing to pass on GST rate reductions effective 01.10.2019; the statutory rebuttable presumption that reduced tax rates require commensurate price reductions was not successfully rebutted. The Respondent's claim of COVID-related additional costs was found unsubstantiated and after-the-fact. The AT directed recovery of Rs. 31,28,631 with interest at 18% p.a. from 01.10.2019 until realization, and ordered deposit of the realized amount into the Consumer Welfare Fund to be apportioned equally between the Centre and States.
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