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    <description>Section 122(1A) of the CGST Act is discussed as reaching not only the taxable person but also the person who retains the benefit of the prohibited transaction and at whose instance it is carried out. On the facts described, the partners were treated as falling within that scope because they retained the benefit and directed the transactions. The note also states that applying Section 122(1A) to conduct that began before 01.01.2021 is not treated as impermissible retrospectivity, because the provision is characterised as identifying the liable person for an existing penal scheme and was in force when proceedings were initiated.</description>
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