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2019 (12) TMI 510

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....Washing Machine (Elena Aqua VX)" (here-in referred to as the product), by not passing on the benefit of reduction in the rate of tax on the impugned product, post introduction of GST w.e.f. 01.07.2017. in this regard; the Applicant No. 1 had relied on two invoices issued by the Respondent, one dated 31.05.2017 (pre-GST) and the other dated 04.08.2017 (post-GST), the details of which have been given in the Table below:- Table - A (Amount in Rs.) S.No. Name of the product supplied Pre-GST rate before 01.07.2017 Post GST rate on 01.07.2017 Difference (in Rs.) Invoice No. & Date Total Tax Total Price (in Rs.) Invoice No. & Date GST rate Total Price (in Rs.) 1. Washing Machine (EIena Aqua VX) (HSN-84501100) 3220057999 dated 31.05.2017 Central Excise duty @ 12.5% the MRP with 35% abetement + [email protected]% 18157/-(base price-13624/-) 3220059299 dated 04.08.2017 28% 23922 (base price-18689/ 5765/- (base price diff.-5065/-) 2. The said complaint was examined by the Standing Committee and vide minutes of its meeting dated 02.07.2018; it requested the DGAP to initiate investigation under Rule 129 (1) of the CGST Rules, 2017 and ....

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....no change in the MRP of the product after GST and he had maintained the same price although the taxable basic value had been reduced and the tax incidence had increased after introduction of GST. He further stated that his factory was situated in Goa and the entire range of products was sold through his branches in different States. In the pre-GST period, the products were stock transferred to his various branches in other States by discharging applicable Central Excise Duty at the time of removal of goods from the factory and he did not charge VAT on the same. In lieu of CST on his stock transferred to other States, the Respondent was reversing the credit of VAT taken on the raw material/inputs used in the manufacture of the product which was amounting to Rs. 24.34 per unit of the product. 6. The Respondent also submitted the Table given below:- Table-B (Amount in Rs.) Details Pre GST period Post GST Period MRP 27,490.00 27,490.00 Excise duty 2,233.56   [email protected]% 3,481.27   G5T@28%   6,013.44 Total Taxes 5,714.83 6,013.44 Basic Price 21,775.17 21,476.56 Reduction in Basic Price 298.61 7. ....

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....the applicable rate of tax in the post-GST period as compared to the pre-GST period in most of the States. The same has been explained in the Table given below:- Table C (Amount in Rs.) 12. The DGAP, from the above table observed that there was a reduction in the rate of tax in respect of States mentioned at S. No. 1 to 16, post introduction of GST w.e.f. 01 07 2017. On the basis of aforesaid pre and post-GST tax rates and the details of outward supplies of the impugned product to the States mentioned at S, Nos. 1 to 16 of Table, during the period 01.07.2017 to 31.08.2018 furnished by the Respondent, the amount of net higher sale realization due to increase in the base price of the product, despite the reduction in the rate of tax post implementation of GST 01.07.2017, or, the profiteered amount was computed as Rs, 51, 04,002/-. The profiteered amount had been arrived at by comparing the State-wise average base price of the impugned product during the period 01,04.2017 to 30.06.2017, with the actual transaction-wise base prices during the period 01.07.2017 to 31.08,2018. 13. The DGAP also furnished a Table in respect of the place of supply of the total profiteered amoun....

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....d product, as charged from his dealer (M/s. Pittapilli Agencies), had actually been reduced from Rs. 21,7751- (pre-GST) to Rs. 21,4761- (post-GST); That the difference in prices pointed out by DGAP was only due to discounts and incentive schemes offered by him to his dealers, and that the details of the same were as below:- Table --E (Amount in Rs.) Product [Elena Aqua VX] Pre-GST Post-GST Invoice No. 3220057999 dated 31-05-2017 Invoice No. 3220059299 dated 04-08-2017 Base Price as per Invoice 24,009 21,476 Excise Duty [INR 2,234/- per unit considered by DGAP] (-) 2,234 - Base Price [excluding all tax elements] 21,776 21,476 Trade Discount as per invoice 2,881 2,786 Net Price Charged 18,894 18,690 (b) That even if the element of Central Excise Duty, as computed by the DGAP, was removed from the above Table computation, the base price charged under the GST was lower than the base price in the pre-GST regime; and the price of the product in pre and post-GST regime be analysed on the basis of the base prices and without considering discounts. The Respondent also cited the precedence of the outcomes in the case ....

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.... on purchases [VAT reversal as considered by DGAP] 0.14% - Total tax incidence on product 26.40% 28% (e) That, since MRP for the product was not increased even when rate of tax, post introduction of GST, was increased from 26.4% to 28%, it was clear that the interest of the consumers had been duly protected. (f) That, even if it was assumed but not admitted that expansion of investigation by the °GAP was valid, the computation of profiteering should have been on the basis of prices charged at a pan India level and not based on prices charged in specific states and specific transactions, since the rationale for anti-profiteering provision was to check that benefit, if any, arising due to introduction of GST was passed on to end consumers and that the expression 'commensurate reduction in prices of the goods' as used in Section 171 of the CGST Act should have been considered for overall reduction in prices and that such expression should not be limited to specific transactions, as in each case the prices depended on independent negotiations with customers/ dealers. Further, he argued that there was no prescription either under the CGST Act or the ....

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....ime, sales made in GST period at price lower than pre-GST average price had been ignored. He also submitted that certain specific sales transactions (employee sales and exchange sales) have been included in computation for pre-GST period but excluded for post GST period. He also submitted that changes in MRP w.e.f. 8th June, 2018, which resulted in consequent change in base price as well had been completely ignored and computation had been made for sale transactions for the period beyond 8th June 18 [i.e., 8th June, 2018 to 31st August, 2018], which were not comparable and during the pre GST as well as post GST period up to 07-06-2018, the MRP remained at Rs. 27,490/- and w.e.f. 08-07-2018, MRP of the impugned product has been changed to Rs. 28,490/-. (j) Once the aforesaid errors were corrected, the position would be as follows, he has claimed:- Table-G (Amount in Rs.) State Average price as per DGAP report Pre-GST [1^st April '17 to 30^th June '17] Post-GST [1^st July '17 to 8^th June '18] Difference between Pre & Post GST Average Prices Sales Realisation Quantity Sold Actual Average Price Sales Realisation Quantity Sold Actua....

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....State code State As per DGAP Report Revised working modifying the aforesaid errors Average Price Alleged Profiteering amount 1 32 Kerala 17,990 27,75,386 -6,70,319 2 33 Tamil Nadu 18,502 15,68,332 -37,503 3 24 Gujarat 18,435 2,20,645 -3,08,213 4 29 Karnataka 17,968 1,08,786 -70,918 5 37 Andhra Pradesh 18,248 1,19,304 -55,806 6 9 Uttar Pradesh 18,375 28,509 -98,718 7 36 Telangana 17,511 62,849 25,400 8 23 Madhya Pradesh 17,661 1,10,908 88,111 9 10 Bihar 18,541 19,987 748 10 19 West Bengal 17,328 30,045 13,774 11 22 Chhattisgarh 17,815 26,000 12,957 12 3 Punjab 17,760 16,904 8,153 13 5 Uttarakhand 18,317 4,690 -17,295 14 18 North East 19,335 1,756 -8,324 15 8 Rajasthan 18,742 641 -7,695 16 1 Jammu & Kashmir - 9,261 - Sub-total for 16 states [as considered by DGAP]   51,04,002 -11,25,648 17 30 Goa 18,556 - -6,16,043 18 07 Delhi 18,930 - ....

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....I) No mechanism/ guideline had been prescribed as to whether the price alteration was required to be done at entity level, State level, product level, SKU level, category level, each of which would bring a different result and there was no guidance whether commensurate change in price would be assessed in absolute terms or as trend or in percentage terms. Further, any initiation of proceeding in present case, when ultimately tax on the product had increased post introduction of the GST regime was also legally unsustainable. (m) The computation of any profiteering based on sale prices and assumption of any increase in sale price as profiteering under GST laws without considering any efficiency in the operations, commercial negotiations, etc., was incorrect and unjustified since a mere change in rate of tax could not be considered as profit which would necessitate reduction in price and that the business of dealer and impact of changes on supply chain ought to be seen as a whole for the purposes of Section 171 of the Act. He also mentioned that it was also imperative to note that GST had also led to various increases in costs like increase in working capital costs, cost of G....

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.... obligations or disabilities through general rule making powers unless the same was specifically contemplated by the provisions of the Act under which such powers were exercised. He also cited the case of Petroleum and Natural Gas Regulatory Board vs. Indraprastha Gas Limited & Ors. (2015) 9 SCC 209 = 2015 (7) TMI 1130 - SUPREME COURT, wherein it had been held that if on reading of the statute in entirety, a power did not flow, a delegated authority could not frame a regulation that would not be in accordance with the statutory provisions. 18. The DGAP vide his Report dated 30.01.2019 on the submissions made by the Respondent dated 11.01.2019, reported that only those invoices had been taken into consideration where the post-GST discounted base price was more than the pre-GST discounted base price. The invoices where the post-GST discounted base price was less than the pre-GST discounted base price, had not been considered by DGAP. Regarding the Respondent's contention of the modalities and mechanism of anti-profiteering, the DGAP reported that the Respondent had mentioned that there was no guideline / methodology for ascertaining the quantum of "profiteering" by the supplier. I....

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....rashtra 4.6% 25.13% 4 Himachal Pradesh 0.2% 25.57% 5 Andhra Pradesh 2.5% 26.25% 6 Kerala 40.8% 26.25% 7 Tamil Nadu 21.6% 26.34% 8 Karnataka 4.5% 26.53% 9 Uttar Pradesh 1.9% 26.70% 10 Gujarat 11.1% 26.81% 11 Bihar 0.5% 27.10% 12 North East 0.1% 27.10% 13 Chhattisgarh 0.4% 27.25% 14 Rajasthan 0.1% 27.73% 15 West Bengal 0.4% 27.74% 16 Madhya Pradesh 0.6% 27.88% 17 Mumbai (Due to Octroi) 0.2% 30.63% (b) That there had been no change in MRP pre and post GST (Rs. 27,490/-) and the applicable GST rate of 28% was higher than the pre-GST rate. (c) That the applicable GST rate was 28% which was higher than the pre-GST rate, thus the question of profiteering did not arise. (d) That the computation of profiteering could not be done based on post discount prices, since in the pre-GST regime, Central Excise Duty was calculated as a percentage of a fixed MRP, but under GST regime, GST was calculated on the basis of the actual price, which was variable. Thus, in case, higher discount was given, then ....

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....e positive numbers (where post-GST base price was higher than the pre-GST base price) to arrive at the profiteering, which was unjustified. He also explained the same with the illustration in Table given below:- Table K: Incorrect Profiteering computed by DGAP based on pre-GST Average Price (Amount in Rs.)   Name of the Dealer/ Customer Pittappillil Agencies QRS Retail Limited Bismi Appliances Nandilath G Mart   (1) (2) (3) (4) Pre-GST base price after discount (A) 18.694 17,953 17,213 17,453 Average Pre GST Base price (B)   17878 Post GST discounted Base price (C) 16,690 17,393 16,536 16,751 Average Post-GST Base price (D) 17343 Actual Reduction In Base Price: actual comparison (E)= (C- A) -204 -560 -677 -702 Actual reduction in Average prices (F) = (D-B) - 535 Increase in Base price as per DGAP method (G) = (C-B) 812 -485 -1342 -1127 Percentage of actual reduction in base price in Post GST 1.09% 3.22% 4.09% 4.19% (f) That from the above table, it was dear that different prices had been charged from different dealers both durin....

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....he average of pre-GST discounted base prices had not been considered by the DGAP. 21. The Respondent filed his next written submissions on 27.02.2019. Vide his submissions; he submitted the dealer wise impact of comparison of prices for sale of product during pre-GST and post GST period i.e. from 01-07-2017 to 07-06-2018 and state wise impact of comparison of prices for sale of the product during pre-GST and post GST period i.e. from 01-07-2017 to 07-06-2018. He also submitted the summary of impact of price reduction on sale of the impugned product during pre and post GST regime with help of a table given below:- Table L: Summary of Impact of price reduction - on sale of Elena Aqua VX during Pre and Post GST regime (Amount in Rs.) State Net Impact Only Positive Only Negative Andhra Pradesh -76,221 9,074 -85,295 Bihar 1,943 5,625 -3,682 Chhattisgarh -4,060 4,397 -8,457 Gujarat -1,56,412 91,292 -2,47,705 Karnataka -55,152 28,914 -84,065 Kerala -8,93,765 1,30,057 -10,23,823 Madhya Pradesh -2,678 11,438 -14,116 Rajasthan -9,609 - -9,609 Tamil Nadu -5,84,633 42,8....

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....nt States could not be considered to arrive at the total applicable tax rate in the pre-GST period as there were more than 1000 dealers to whom the Respondent had made supplies in the pre-GST period as also the post-GST period and it was not possible to compare the pre-GST and post-GST base prices in respect of each dealer separately. DGAP further submitted that the investigation was conducted based on the average of the discounted base prices during the pre-GST period separately for each State which were then compared with the actual invoice-wise discounted base prices in the post-GST period for each of the States separately and that he had adopted this line of investigation uniformly for all the cases. (c) That only those invoices had been taken into account for computing profiteering, where the post-GST discounted base prices were higher than the average pre-GST discounted base price. The invoices where the post-GST discounted base prices were lower than the average pre-GST discounted base prices had not been considered since these did not reflect profiteering. The DGAP mentioned that, the Respondent's claim of increasing the MRP from Rs. 26,990/- to Rs. 27,490/-, in th....

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....gana 90596 13 9 Uttar Pradesh 47015 14 5 Uttarakhand 4704 15 19 West Bengal 38429 Total 68,28,592 Table 01.07.2017 to 06.06.2018 S.No. State Code State (Place of Supply) Profiteering (Rs.) 1 37 Andhra Pradesh 84568 2 10 Bihar 26738 3 22 Chhattisgarh 19877 4 24 Gujarat 336149 5 29 Karnataka 108166 6 32 Kerala 1754329 7 23 Madhya Pradesh 116156 8 18 Assam 1225 9 3 Punjab 15031 10 8 Rajasthan 840 11 33 Tamil Nadu 1236809 12 36 Telangana 31220 13 9 Uttar Pradesh 41065 14 5 Uttarakhand 4570 15 19 West Bengal 20901 Total 37,97,663 The DGAP further stated that the Authority might decide as to which period should be considered i.e. up to 31.08.2018 or 06.06.2018. 23. The Respondent filed his next written submission on 22.04.2019, vide which he stated that:- (a) The DGAP vide his report dated 15.03.2019 had compared the tax rates applicable during period prior to and post introduction of GST which was beyond the ambit of Section 17....

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....11 (4) TMI 1275 - SUPREME COURT which stated that "It is a settled principle of statutory interpretation that any compulsory exaction of money by the Government such as a tax or a cess has to be strictly in accordance with law and for these reasons a taxing statute has to be strictly construed. AS observed by this court in Ahmadabad Urban Development vs. Sharad kumar Joyanti kumar Pasawalla, (1992) 3 SCC 285 = 1992 (5) TMI 175 - SUPREME COURT, it has been consistently held by this court that whenever there is compulsory exaction of money, there should be specific provision for the same and there is no room for intendment and nothing is to be read or nothing is to be implied and one should look fairly to the language used." (ii) CCE (Import), Mumbai vs. Dillip Kumar and Company and Ors, MANU/SC/0789/2018 = 2018 (7) TMI 1826 - SUPREME COURT which stated that "After thoroughly examining the various precedents some of which were cited before us and after giving our anxious consideration, we would be more than justified to conclude and also compelled to hold that every taxing statute including, charging, computation and exemption Clause (at the threshold st....

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.... the same was not due to change in tax rate but due to business marketing reasons. He also submitted that the Analysis carried out by DGAP at discounted prices was against the principles laid down by the Authority, particularly because pre-GST tax rates were based on MRP and in GST, it was ad valorem. The Respondent further submitted that the proceedings in the present matter were barred by limitation prescribed under Rule 133(1) of the COST Rules, 2017, in terms of the response by the DGAP dated 11.06,2019 since proceedings were required to be completed within a period of 3 months from the date of receipt of report from DGAP and in the present case, the DGAP's report under Rule 129 (6) was submitted to the Authority on 0612.2018. Thus, time limit as prescribed under Rule /33(1) had already lapsed and the present proceedings were time barred. 26. The DGAP vide his submissions dated 09,07.2019 had stated that all the issues raised by the Respondent had already been discussed in his previous report dated 06.12,2018 and 15.03.2019 submitted to the Authority. 27. We have carefully considered the material placed before us and all submissions made by the Respondent and by the DGAP.....

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.... to one recipient cannot be offset with the denial of benefit to another recipient, as this is not the spirit of the law. Since, the Respondent's interpretation of Section 171 of CGST Act, 2017, doesn't have any legal merit, it cannot be accepted. 29. The Respondent has also claimed that the prices charged by him from his dealers post introduction of GST had actually reduced and the net impact of such price change was negative and while comparing the average price for pre-GST period with sales transactions in post GST regime, sales made in GST period at price lower than pre-GST average price had been ignored, But this contention is not correct since aggregate profiteering has to be computed on the basis of what each consumer has lost due to non-reduction of the prices in a commensurate manner by the Respondent. 30. The Respondent has referred Kerala State Screening Committee and another Vs. M/s. Asian Paints Ltd. [Case No. 29/2018 decided on 27.12.2018] = 2019 (1) TMI 21 - NATIONAL ANTI-PROFITEERING AUTHORITY, Kerala State Screening Committee and another Vs. M/s Peps Industries Pvt. Ltd [Case No. 22/2018 decided on 27.09.2018] = 2018 (12) TMI 1402 - NATIONAL ANTI-PROFITEERING....

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.... entity/registrant is the sum total of all the benefits that stood denied to each of the recipients/consumers individually. The intent of the words "commensurate reduction" is also clearly explained by the words "by reduction in price". 33. The Respondent has also placed reliance on the judgement of the Hon'ble Supreme Court passed in the case of Commissioner Central Excise and Customs Kerala v. Larsen and Toubro Limited (2016) 1 SCC 170 = 2015 (8) TMI 749 - SUPREME COURT. However, it is respectfully submitted that in the above case the issue involved was pertaining to the lack of machinery for enforcing the levy of Service Tax however, in the present case no tax has been levied and hence the law settled in the above case does not apply. 34. The Respondent further cited the judgements of the Hon'ble Supreme Court in the cases of Consumer Online Foundation and Others vs Union of India and Others, (2011) = 2011 (4) TMI 1275 - SUPREME COURT, CCE (Import), Mumbai vs Dillip Kumar and Company and Ors, = 2018 (7) TMI 1826 - SUPREME COURT CIT vs B. C. Srinivasa Shetty [(1991) 2 SCC 460] = 1981 (2) TMI 1 - SUPREME COURT in his support which pertain to the interpretation of the statute....

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....ed at a pan India level and not based on prices charged in specific states and specific transactions. This contention of the Respondent is also incorrect since profiteering is computed by the DAP only in respect of the States where the rate of tax was increased from pre-GST to post-GST, thus the DGAP has rightly computed the profiteering. The Respondent further queried that since the instant enquiry was meant only for the State of Kerala and hence, the inclusion of certain other States in the study and exclusion of some others was unjustified. In our opinion, this contention of the Respondent does not hold good since Section 171(1) and (2) of the CGST Act state as follows:- "(1) Any reduction in rate of tax on any supply of goods or services or the benefit of input tax credit shall be passed on to the recipient by way of commensurate reduction in prices. (2) The Central Government may, on recommendations of the Council, by notification, constitute an Authority, or empower an existing Authority constituted under any law for the time being in farce, to examine whether input tax credits availed by any registered person or the reduction in the tax rate have actually r....

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....s Authority by the Central Govt., as per the provisions of Section 164 of the above Act which has approval of the Parliament. Rule 126 has further been framed on the recommendation of the GST Council which is a constitutional body created under the Constitution (One Hundred and First Amendment) Act, 2016, Therefore, the above power has both legislative sanction as well as incorporation in the CGST Act, 2017 and the CGST Rules, 2017. The delegation provided to this Authority under the above Rule is clear, precise, unambiguous and necessary and is well within the provisions of the Constitution and therefore, it has been rightly conferred on this Authority. Hence, the objections raised by the Respondent in this regard are frivolous and without legal force. 39. The Respondent also contended that there were no provisions in the Act for penal action as provided in the Rule 133 and there can be no invocation of the penal provisions in the present case. It is incorrect since the power of imposition of penalty is duty assigned by the CGST Act, 2017 and Rule 127 (iii) (c) and Rule 133 (3) (d) of the CGST Rules, 2017 to the Authority. 40. The Respondent has also contended that the calcu....

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....iled in table I). The table K also supersedes the table C which was originally relied by the DGAP. We find that the table K is an elaborate computation of the effective state wise tax rates and the reduction in the rate of tax state wise. Hence, the table K submitted by the DGAP is correct. 42. Another contention of the Respondent is that the proceeding was barred by limitation prescribed under Rule 133(1) of the CGST Rules, 2017 since proceedings were required to be completed within a period of 3 months from the date of receipt of report from DGAP i.e. from 06.12.2018. But this contention is not correct since the DGAP had submitted his last Report on 11.06.2019 and vide Notification No. 31/2019-Central Tax dated 28.06.2019 of the Central Board of Indirect Taxes and Customs the time period for the Authority to pass the order from the date of the report of DGAP was increased to 6 months as amendment in Rule 133(1) thus, taking the 11.06.2019 as date of receipt of report from the DGAP, the time limit of 6 months has still not been completed. 43. Further, the DGAP's vide his report dated 15.03.2019 had also clarified that the Respondent vide his submissions dated 27,02.2019 had ....

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.... the above amount is deposited in terms of the Rule 133 (3) (b) of the CGST Rules, 2017. Since, rest of the recipients in this case are not identifiable, the above Respondent is directed to deposit the amount of profiteering of Rs. 67, 28,592/- along with interest in the Consumer Welfare Fund of the Central and the concerned State Governments as per the provisions of Rule 133 (3) (c) of the CGST Rules, 2017 in the ratio of 50:50 in the Central and State CWFs along with interest @ 18% till the same is deposited. Accordingly, an amount of Rs. 33,64,296/- will be deposited in the Central Consumer Fund while the balance will be deposited in the State CWFs as shown in the table given below:- S.No. State Code State (Place of Supply) Total Profiteering (Rs.) 1. 37 Andhra Pradesh New 76946 2. 10 Bihar 15041.50 3. 22 Chhattisgarh 16121 4. 24 Gujarat 244988 5. 29 Karnataka 89610.50 6. 32 Kerala 1729947 7. 23 Madhya Pradesh 66246.50 8. 18 Assam 1047.50 9. 3 Punjab 9592 10. 8 Rajasthan 420 11. 33 Tamil Nadu 1023964 12. 36 Telangana 45298 ....

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.... consumers in contravention of the provisions of Section 171 (1) of the CGST Act, 2017 and has thus resorted to profiteering. Hence, he has committed an offence under Section 171 (3A) of the CGST Act, 2017 and therefore, he is apparently liable for imposition of penalty under the provisions of the above Section. Accordingly, a Show Cause Notice be issued to him directing him to explain why the penalty prescribed under Section 171 (3A) of the above Act read with Rule 133 (3) (d) of the CGST Rules, 2017 should not be imposed on him. Accordingly, the notice dated 13.12.2018 vide which the Respondent was directed to show cause why action under Section 29 and 122-127 of the CGST Act. 2017 should not be taken against him is hereby withdrawn. 48. A copy of this order be sent to the Applicants and the Respondent free of cost. File of the case be consigned after completion. ============= Document 1 Avera ge Central base Excise price Duty@12 VAT S No pre .5% on State Total Rate Total Total Applicable Average Applic Tax Rate of VAT credit in le tax lieu of GST MRP VAT able (VAT+ Reversal Total Applicab GST rate....

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.... 12.50 2646 4880 22. Haryana 19035 21269 12.50 2234 2659 4893 25.77% 0.13% 25.70% 0.13% 5023 27.26% 0.13% 27.39% 4833 26.04% 0.00% 26.04% 28% 25.90% 28% -0.61% -1.96% 28% -2.10% 25.83% 28% -2.17% Document 3 Averag Central e base price Excise Revers Duty@12 pre VAT Total Applicab Total le Tax .5% on S No State GST Total Average Rate MRP Applica Rate VAT April with 35% (%) to abateme Excise) rate w.e.f. rate of ble tax (VAT of CST Pre-GSTP1.07.20 Tax al of Total VAT Applicab credit in lieu GST Reducti on in le tax Rate June nt (%) (%) 17 (%) (%) (%) 2017 G=C A B с D=B+C F=D'E/100 +F H=G/B* 100 J K L 1 West Bengal 17311 2222 19534 14.5 2832 5055 29.20 0.14 29.34 28 1.34 2 Telangana 17406 2234 19640 14.5 2848 5081 29.19 0.14 29.33 28 1.33 3 Gujarat 18187 2234 20421 15 3063 5297 29.12 0.14 29.26 28 1.26 4 Punjab 17800 2234 20034 14....