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    <title>2026 (7) TMI 311 - GSTAT NEW DELHI-[PB]</title>
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    <description>Where additional Input Tax Credit benefit was not fully passed on to 149 eligible homebuyers up to receipt of the Occupancy Certificate, the profiteering was quantified on the accepted investigation methodology and the remaining amount was directed to be refunded with interest at 18% per annum under Rule 133(3)(b). Penalty under Section 171(3A) was declined because the alleged contravention had ended before that penal provision became operative on 01.01.2020; a penalty provision cannot apply retrospectively to conduct fully completed earlier.</description>
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      <description>Where additional Input Tax Credit benefit was not fully passed on to 149 eligible homebuyers up to receipt of the Occupancy Certificate, the profiteering was quantified on the accepted investigation methodology and the remaining amount was directed to be refunded with interest at 18% per annum under Rule 133(3)(b). Penalty under Section 171(3A) was declined because the alleged contravention had ended before that penal provision became operative on 01.01.2020; a penalty provision cannot apply retrospectively to conduct fully completed earlier.</description>
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