TaxTMI 
TaxTMI 
2022 (5) TMI 783
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....not been passed on to the Applicant No. 1 by way of commensurate reduction in price and if so, to suo moto determine the quantum thereof and indicate the same in his reply to the Notice as well as furnish all supporting documents. Vide the said Notice, the Respondent was also given an opportunity to inspect the non-confidential evidences/information furnished by the Applicant No. 1 during the period 10.08.2020 to 12.08.2020. However, the Respondent did not avail of this opportunity. 2. The DGAP has also stated that the period covered by the current investigation was from 01.07.2017 to 30.06.2020. 3. Further, the DGAP has reported that the time limit to complete the investigation was 16.01.2021. However, in terms of Notification 35/2020-Central Tax dated 03.04.2020 where, any time limit for completion/furnishing of any Report, had been specified in, or prescribed or notified under the CGST Act, 2017 which falls during the period from the 20th day of March, 2020 to the 29th day of June, 2020, and where completion or compliance of such action had not been made within such time, then, the time limit for completion or compliance of such action, should be extended upto the 30.06.20....
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....d not avail of. 8. Further, the DGAP has also submitted that the subject application, various replies of the Respondent and the documents/evidences on record had been carefully examined. The main issues for determination were: - (i) Whether there were benefit of reduction in rate of tax or ITC on the supply of Construction S (ii) Service by the Respondent after implementation of GST w.e.f. 01.07.2017 and if so, (iii) Whether the Respondent passed on such benefit to the recipients by way of commensurate reduction in price, in terms of Section 171 of the CGST Act, 2017. 9. The DGAP has further stated para 5 of Schedule-III of the CGST Act, 2017 (Activities or Transactions which should be treated neither as a supply of goods nor a supply of services) which reads as "Sale of land and, subject to clause (b) of paragraph 5 of Schedule II, sale of building". Further, clause (b) of Paragraph 5 of Schedule II of the CGST Act, 2017 reads as "(b) construction of a complex, building, civil structure or a part thereof, including a complex or building intended for sale to a buyer, wholly or partly, except where the entire consideration has been received after iss....
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....- GST) April, 2016 to June, 2017 Turnover (July, 2017 to June, 2020) 1. CENVAT of Service Tax Paid on Input Services (A) 4,80,360 - 2. ITC of VAT Paid on Purchase of Inputs (B) - 3. Total CENVAT/ VAT on Purchase of Inputs (C)=(A+B) 4,80,360 - 4. ITC of GST Availed (D) - 1,10,82,436 5. Turnover for Residential Flats as per Home Buyers List (E) 4,97,09,637 29,65,75,363 6. Turnover for Commercial as per Home Buyers List (F) 12,00,000 5,47,27,824 7. Total Turnover for Flats & Commercial as per Home Buyers List for Residential Flats (G) = (E + F) 5,09,09,637 35,13,03,187 8. Total Saleable Area for Residential Flats (in SQMT) (H) 12.202 12,202 9. Total Saleable Area for Commercial (in SQMT) (I) 3,138 3,138 10. Total Saleable Area for Residential Flats & Commercial (in SQMT) (J) = (H+I) 15,340 15,340 11. Total Sold Area for Residential Flats (in SQMT) relevant to turnover (K) 3,490 10,304 12. Total Sold Area for Commercial (in SQMT) relevant to turnover (L) 116 1,388 13. Total Sold Area for Residential Flats & Commercial (in SQMT) ....
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....demand price J=H+I 32,49,23,222 5,99,58,928 38,48,82,151 Excess Collection of Demand or Profiteering Amount K=G-J 72,41,184 13,36,235 85,77,419 13. The DGAP has stated that from Table-'B' above, it was clear that the additional ITC of 2.18% of the turnover should have resulted in the commensurate reduction in the base price as well as cum-tax price. Therefore, in terms of Section 171 of the CGST Act, 2017, the benefit of such additional ITC was required to be passed on to the recipients. 14. The DGAP has further reported that having established the fact of profiteering, the next step was to quantify the same. On the basis of the aforesaid CENVAT/ITC availability pre and post-GST and the details of the amount collected by the Respondent from the Applicant No. 1 and other home buyers during the period 01.07.2017 to 30.06.2020, the amount of benefit of ITC that needed to be passed on by the Respondent to the recipients or in other words, the profiteered amount came to Rs. 85,77,419/- for residential flats and commercial shops, which included 12% GST on the base profiteered amount of Rs. 76,58,409/-. This amount was inclusive of profit....
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.... shall be passed on to the recipient by way of commensurate reduction in prices", had been contravened in the present case. 19. The above Report was carefully considered by this Authority and a Notice dated 05.01.2021 was issued to the Respondent to explain why the Report dated 29.12.2020 furnished by the DGAP should not be accepted and his liability for profiteering in violation of the provisions of Section 171 should not be fixed. The Respondent was directed to file his written submissions which had been filed on 27.02.2021 wherein the Respondent has submitted:- i. That the Standing Committee had erred in referring the matter to the DGAP for further investigation:- a. As per Rule 128(1) of the CGST Rules, 2017 on receipt of an application, the Standing Committee should examine the accuracy and adequacy of the evidence provided in the application to determine whether there was prima facie evidence to support the claim of the Applicant No. 1 that the benefit of reduction in the rate of tax on any supply of goods or services or the benefit of ITC had not been passed on to the recipient by way of commensurate reduction in prices. b. In the present case, ....
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....e Council, by notification, constitute an Authority, or empower on existing Authority constituted under any law for the time being in force to examine whether ITC availed by any registered person or the reduction in the tax rate have actually resulted in a commensurate reduction in the price of the goods or services or both supplied by him. (3) The Authority referred to in sub-section (2) should exercise such powers and discharge such functions as may be prescribed." c. Chapter XV of the CGST Rules contains Rules regarding anti-profiteering. Rule 128 of the CGST Rules contains provisions regarding the examination of application by the Standing Committee and Screening Committee. The extract of the Rule has been provided below for quick reference: "128. Examination of application by the Standing Committee and Screening Committee:- (1) The Standing Committee shall, within a period of two months from the date of the receipt of a written application, in such form and manner as may be specified by him from an interested party or from a Commissioner or any other person. examine the accuracy and adequacy of the evidence provided in the application to det....
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....visions of Section 171 limited its Order only to the particular model of Almirah. f. The application in an anti-profiteering case acts as foundation and base of an investigation. In the present case, the application was received merely by Applicant No. 1 for the Flat bearing No. D-701, Krish Elite at Nikol Ahmedabad. Hence, the investigation could not go beyond the application and should not cover other customers also who had not questioned the benefit passed on to them. g. The DGAP could not suo mote assume jurisdiction with regard to other customers of the Respondent, on receipt of reference from the Standing Committee to conduct a detailed Investigation in the matter of Applicant No. 1. It was also submitted that the DGAP could not exceed his Jurisdiction by submitting its findings for other unit buyers and recipients who had not filed any application without any reference from the Authority in this regard. h. An application filed by a dissatisfied Applicant No. 1 might be compared to a Show Cause Notice for a tax proceedings wherein the assessee were required to show cause as to why tax, interest, penalty, etc. should not be levied and collected from ....
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....Central Tax) notified the Anti-profiteering Rules which provide for constitution of authority, standing committee and steering committee, power to determine the methodology and procedure, duties of authority, examination of application, order of the authority, compliance by the registered person etc. c. Rule 126 of the CGST Rules contains provisions regarding the power to determine methodology and procedure. The extract of the relevant portion of the rule has been provided below for quick reference: "Rule 126- power to determine the methodology and procedure:- The Authority may determine the methodology and procedure for determination as to whether the reduction in the rate of tax on the supply of goods or services or the benefit of input tax credit has been passed on by the registered person to the recipient by way of commensurate reduction in prices." d. As per Rule 126, the Authority had the power to determine the methodology and procedure for determination as to whether the reduction in rate of tax on the supply of goods or services or the benefit of ITC had been passed on by the registered person to the recipient by way of commensurate reduc....
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....ring measures in Australia revolved around the Net Dollar Margin Rule" serving as the fundamental principle for its guidelines. That was, if the new tax scheme - GST in this case-caused taxes and costs to fall by $1, then prices should fall by at least $1. At the same time if the cost of the business rose by $1 under the new tax scheme, then prices might rise by not more than $1. These regulations have been set as barometers for calculating profiteering. J. No such procedure for calculation of profiteering had been provided under the CGST Act and CGST Rules. Absence of the same violates the principles of natural justice and thus, the investigation was liable to be set aside. k. In this regard, reliance was placed on the case of Eternit Everest Ltd. vs. UOI, reported at 1997 (89) E.L.T. 28 (Mad), where the Hon'ble Madras High Court held that in absence of machinery provisions pertaining to determination and adjudication upon a claim or objection, the statutory provision would not be applicable. I. In the case of Commissioner of Income Tax, Bangalore vs. B.C. Srinivasa Setty, reported at (1981) 2 SCC 460, the Hon'ble Supreme Court held that charging....
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....re was no correlation of turnover with the cost of construction or development of a project. The turnover reflected the amount collected as per payment or booking plans issued by the developer which was dependent upon market driven strategy. On the contrary, the ITC was accrued to a developer on the basis of actual cost incurred by it while undertaking the development of a project. Thus, accrual of ITC was not dependent on the amount collected from the buyers. As mentioned earlier, in this industry, advance was received by the suppliers/dealers even before the commencement of the projects. Likewise, units were sold after the completion of the project as well. Thus, receiving of inputs/input services and taking credit of the same did not have an immediate and direct relation with the turnover. Accordingly, calculating profiteering on the basis of turnover could not reflect the correct outcome for the Respondent. c) To understand the above submission through an illustration, a case was cited as an example wherein the developer floats 25/75 scheme for one of its projects which was launched under the pre-GST regime. As per the scheme, the unit buyers/applicants were required t....
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....spondent in terms of Section 171 of the CGST Act should reflect such ITC on goods or services which was not available earlier to the Respondent. However, the approach adopted by the DGAP for calculating the additional benefit accrued to the Respondent was based on the change in rate of tax on input goods and services in the GST regime itself. It was pertinent to mention that credit with respect to such inputs/input services was available to the Respondent earlier as well before the change in the rate. Further, the DGAP had not considered the tax cost which was earlier blocked in the hands of the Respondent. Hence, the above approach of comparison of ITC to turnover ratio for pre-GST and post GST period for a limited period steal of project duration was not a correct approach and profiteering computed on basis of the same was liable to be set aside on this count itself. v. That the calculation made by the DGAP of the alleged profiteering was incorrect. On application of correct calculation the alleged profiteering figures were less than costs incurred by the respondent:- a) Applying the methodology adopted by the DGAP in his Report, it was submitted that the calcul....
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.... and 129 of the CGST Rules, 2017. The Standing Committee was neither an investigating agency nor an adjudicating Authority. The Standing Committee examines the accuracy and adequacy of the evidence provided in the application to determine whether there was prima-facie evidence to support the claim of the Applicant No. 1 that the benefit of reduction in the rate of tax on any supply of goods or services or the benefit of ITC had not been passed on to the recipient by way of commensurate reduction in prices. Further in the matters, where the Standing Committee was satisfied that was a prima-facie evidence to show that the supplier had not passed on the benefit of reduction in the rate of tax on the supply of goods or services or the benefit of ITC to the recipient by way of commensurate reduction in prices, the matter was referred to the DGAP for a detailed investigation. b) For the averment made by the Respondent that the Report could not go beyond the application submitted by the Applicant No. 1 vide letter dated 27.01.2019, the DGAP has clarified that as per Section 171 (1) of the CGST Act, 2017 which itself states that "Any reduction in rate of tax on any supply of goods....
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....rifications and to elaborate upon the legislative intent behind the law, the Authority had been empowered to determine/expand the procedure and methodology in detail. However, one formula which fits all could not be set while determining such a "Methodology and Procedure" as the facts of each case were different. In one real estate project, date of start and completion of the project, price of the house/commercial unit, mode of payment of price, stage of completion of the project timing of purchase on inputs, rates of taxes, amount of ITC availed, total saleable area, area sold and the taxable turnover realized before and after the GST implementation would always be different than the other project and hence the amount of benefit of additional ITC to be passed on in respect of one project would not be similar to another project. Issuance of Occupancy Certificate/Completion Certificate would also affect the amount of benefit of ITC as no such benefit would be available once the above certificates were issued. Therefore, no set parameters could be fixed for determining methodology to compute the benefit of additional ITC which would be required to be passed on to the buyers of such u....
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....it due to ITC admissibility during GST period and thereby pocketing the increased ITC gain instead of transferring the same to the ultimate consumer. iii. In those cases where businesses had gained due to the ITC should pass on the benefits to the ultimate consumer by commensurate reduction in their prices. iv. The term profit implied the comparison of income vs. expenses. The Respondent submitted that in order to arrive at the value of profit during GST period one needed to make the comparison with increased income/gain vs. consequent increase in cost/loss. The Respondent submitted that by considering the increased income/gain as absolute factor to arrive at the profit amount would tantamount to envisaging factious profit which were grossly incorrect and mis-leading. v. In order to arrive at the actual profiteering amount during GST period the increased income i.e. the ITC gained during GST period and the increase in cost of goods/ services supplied during GST period should be compared and thereby arrived at the actual profit value. vi. The DGAP in his Report had not only ignored the factual details of the escalation in cost of constructions sup....
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....legislations due respect to their independent provisions and jurisdiction should be provided. vii. Section 171 of the CGST Act, 2017 was not non obstante clause thereby overriding its impact over all the other legislation. The harmonious construction of Section 171 of CGST Act, 2017 when read with the Contract Act & Transfer of Properties Act would mean that in respect of those contracts which was executed prior to introduction of GST and wherein consideration for such contract was already determined could be re adjusted to provide for profiteering impact if any due to introduction of GST. viii. Those Contracts / agreernents executed during GST period have already factored in profiteering impact due to introduction of GST at the time of arriving at the value of consideration by respecting the provisions of Section 171 of CGST Act, 2017. ix. The presumption of the DGAP that no concession had been considered at the time of executing the sale of flats / shops during GST period was arbitrary, ultra-virus to Contract Act & Transfer of property Act and in abundant violation of Rule of Caveat Emperor. x. There was no implication of Section 171 of CGST A....
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....ing to the DGAP the Respondent had gained ITC of Rs. 84,47,070/- after introduction of GST. ix. At Sr. No. 12 of Table-B of the DGAP's report dated 29.12.2020, the "Excess Collection of Demand or Profiteering Amount" for period Jul-17 to Jun-20 were worked out by the Ld. DG as Rs. 85,77,419/- (Emphasis supplied) It meant that according to the DGAP the Respondent had profited / collected excess amount from the customers to the tune of Rs. 85,77,4191- after introduction of GST and thereby not reducing the price of the flats / shops sold by him. x. The Respondent failed to understand as to how the DGAP's report had indicated gain ITC of Rs. 84,47,070/- during GST period and against which they should have reduced the price to the extent of Rs. 85,77,419/-. d) That Profiteering if any should be limited to flats / shops sold before the receipt of Building Use (BU) permission:- i. Assuming but without admitting to the fact that the methodology adopted by the DGAP was correct then also the benefit on account of alleged profiteering should be limited to those units of flats and shops, which was said before the receipt of BU permission and on which....
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....,57,35,890 9. Recalibrated Base Price H=E*(1-D) or 97.82% of E 12,64,67,920 4,44,86,407 17,09,54,327 10. GST @12% I=H*B 1,51,76,150 53,38,369 2,05,14,519 11. Commensurate demand price J=H+I 14,16,44,070 4,98,24,776 19,14,68,846 12. Excess Collection of Demand or Profiteering Amount K=G-J 31,56,657 11,10,387 42,67,044 vi. In any case the alleged profiteering amount of Rs. 85,77,420/- was not sustainable and deserved to be quashed. e) That the DGAP's Report was vague:- i. The Report submitted by the DGAP was basic foundation of proceedings which might give rise to different consequences of law. Composite Report of findings issued by the DGAP left the matter in dark. ii. Impugned Report presupposed the facts and figures as submitted hereinabove regarding the non- consideration and/or factoring of the GST ITC impact at the time of sale of new flats and shops during GST period. The Respondent submitted that the scientific and logical reasons behind the adoption of the methodology to work out the alleged profiteering amount was not discussed or explained. iii. The hypo....
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....e same should be set aside. The Respondent submitted that the investigation initiated by the DGAP and the Report submitted by him was in gross violation of principle of natural justice. The Respondent had never been called upon before determining the alleged profiteering amount. He had not been given an opportunity to explain his submissions, documents inspite of the fact that the Respondent had always requested in writing in all his submission before the DGAP. iii. In case of D.P Mahesh vs. Assistant Commissioner (CT) (Addl.), Thiruvanmiyur Assessment Circle, Chennai [2013] 58 VST 434 (Mad.) wherein the Respondent i.e. Assistant Commissioner had passed the impugned order which amounted to violation of the principles of natural justice Considering the facts and circumstances of the case and in the interest of justice. The impugned assessment order dated 18.05.2012 was quashed with a direction to the Respondent i.e. Assistant Commissioner to consider the matter afresh after giving opportunity to the petitioner. iv. In case of Palaniappa Sago Factory vs. DCTO Attur Assessment Circle (2009) 24 VST 248) wherein reasonable opportunity was not given to the petitioner si....
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....missioner, Commercial Tax Department Vs. Shukla & Brothers reported at 2010 (254) ELT 6 (SC)=2011 (22) STR 105 (SC), importance of principle of natural justice and its strict adherence has been upheld. v. The impugned Report of DGAP being a non-speaking had been passed in gross violation of principles of equity fair play and natural justice. Therefore, the impugned Report was liable to be set aside on this ground alone. 22. The above supplementary written submissions of the Respondent dated 05.04.2021 were sent to the DGAP for reply/clarifications under Rule 133 (2A) of the CGST Rules. A Supplementary Report dated 14.03.2022 was received from the DGAP wherein he has, inter-alia, clarified:- a. That for the contention raised by the Respondent that cost of construction in GST era had increased many folds thereby neutralizing the ITC gained during GST era it was stated that the mandate of Section 171 is limited to the extent of protecting the interest of consumers by ensuring that both the benefits of tax reduction and ITC which are sacrificed by the Central and State Governments from precious tax revenue, need to be passed on to the end consumers who bear the bur....
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....ing if any should be limited to flats/shops sold before the receipt of Building Usage (BU) permission. In this connection it was stated that the Respondent had not submitted the detail of Occupancy Certificate during investigation. The Report had been prepared on the basis of the data/Details submitted by the Respondent from July 2017 to June 2020. Even in his own calculation in Table-B at para D-5 of written submissions dated 05.04.2021, the Respondent had not mentioned the date of Occupancy Certificate. Therefore, this allegation was not sustainable. e. That for the contention raised by the Respondent that the DGAP's Report was vague it is submitted that the allegation of the Respondent was not sustainable, as the Report of the DGAP was prepared after due consideration of all the factors and on the basis of Procedure and Methodology prescribed by this Authority. The case law quoted by the Respondent SBQ Steels Ltd. Vs. Commissioner of Customs, C.Ex., & ST., Guntur 2014 (300) ELT 185 (AP), CCE vs. Shemeo India Transport 2011 (24) STR 409 (tri-del) and Amrit Food vs. CC 2005 (190) ELT 433 (SC) were not relevant to the present case. f. That the Respondent raise....
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....rved that the ITC, as a percentage of the turnover, that was available to the Respondent during the pre-GST period (April-2016 to June-2017) was 0.22%, whereas, during the post-GST period (July-2017 to June, 2020), it was 2.40%. 27. The Respondent vide his various written submissions has contended that the Standing Committee had erred in referring the matter to the DGAP for further Investigation. The Authority finds that as per Rule 123 of the CGST Rules, 2017, the Standing Committee and the Screening Committees at the State level are mandated to carry out only prima facie examination of the allegations of profiteering and, if found true, which are to be investigated by the DGAP in detail under Rule 129 (1) of the Rules. Hence, the contention raised by the Respondent is not correct in as much as prima facie the above Committees have found evidence to the effect that the ITC benefit has not been passed on by the Respondent. 28. The Respondent has contended that the Report of the DGAP could not go beyond the application submitted by the Applicant No. 1. The Authority notes that, in terms of Section 171 (1) of the CGST Act, 2017, it is mandated that, "Any reduction in rate of ta....
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....as stated that the ITC value adopted in the DGAP's Report was incorrect and erroneous. In this regard, the Authority finds that, the Report of the DGAP was prepared after due consideration of all the factors and data submitted by the Respondent in accordance with the 'Procedure and Methodology' prescribed by this Authority. The 'Procedure and Methodology' for passing on the benefits of reduction in the rate of tax and the benefit of ITC are enshrined in Section 171 (1) of the CGST Act, 2017 itself which states that "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". As the benefit of ITC has not been passed on by the Respondent to his home/shop buyers, therefore, he has violated the provisions of Section 171 of the CGST Rules, 2017 and therefore in the light of the above, the contention of the Respondent is not sustainable. The case laws quoted by the Respondent i.e. SBQ Steels Ltd. Vs. Commissioner of Customs, C.Ex., & ST., Guntur 2014 (300) ELT 185 (AP), CCE vs. Shemeo India Transport 2011 (24) STR 409 (Tri-Del) and Amrit Food vs. CC....
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....One formula which fits all cannot be set while determining such a "Methodology and Procedure" as the facts of each case are different. In one real estate project, date of start and completion of the project, price of the house/commercial unit, mode of payment of price, stage of completion of the project, timing of purchase of inputs, rates of taxes, amount of ITC availed, total saleable area, area sold and the taxable turnover realized before and after the GST implementation would always be different than the other project and hence the amount of benefit of additional ITC to be passed on in respect of one project would not be similar to another project. Issuance of Occupancy Certificate/ Completion Certificate would also affect the amount of benefit of ITC as no such benefit would be available once the above certificates are issued. Therefore, no set parameters can be fixed for determining methodology to compute the benefit of additional ITC which would be required to be passed on to the buyers of such units. Further, the facts of the cases relating to the Fast Moving Consumer Goods (FMCGs), restaurants, construction and cinema houses are completely different and therefore, the ....
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....hat has been profiteered by the Respondent from his home buyers (as per the list mentioned below), including Applicant No. 1, and shall be refunded by him along with interest @18% thereon, from the date when the above amount was profiteered by him till the date of such payment, in accordance with the provisions of Rule 133 (3) (b) of the GCST Rules 2017. 35. We find no reason to differ from the above-detailed computation of profiteering by the DGAP. This Authority under Rule 133 (3) (a) of the CGST Rules, 2017 orders that the Respondent shall reduce the prices to be realized from the buyers of the flats/shops commensurate with the benefit of ITC received by him as has been detailed above. 36. We also order that the profiteering amount of Rs. 85,77,419/- shall be passed on along with the interest @ 18% to be passed on to the home/shop buyer from the date when the above amount was profiteered by him till the date of such payment by the Respondent within a period of 3 months from the date receipt of this order. The amounts to be refunded to each individual home/shop buyers is as per Annexure 'A' to this order. Such amount shall be refunded with appropriate interest @ 18%....
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....ubsequent Order dated 10.01.2022 has extended the period(s) of limitation till 28.02.2022 and the relevant portion of the said Order is as follows:- "The Order dated 23.03.2020 is restored and in continuation of the subsequent Orders dated 08.03.2021, 27.04.2021 and 23.09.2021, it is directed that the period from 15.03.2020 till 28.02.2022 shall stand excluded for the purposes of limitation as may be prescribed under any general of special laws in respect of all judicial or quasi-judicial proceedings." Accordingly this Order having been passed today falls within the limitation prescribed under Rule 133 (1) of the CGST Rules, 2017. 42. A copy of this order be supplied to the Applicants and the Respondent. File of the case be consigned after completion. Enclosed: Annexure 'A' (page 1 to 10) ============= Document 1 Sr. Name of Homebuyer No. 1 Annexure 'A' GEETABEN PURUSHOTTAM BHAI MEWADA Residential Unit No. Amount of profiteering B-103 23195.2 2 ANITA DINESHCHANDRA AMAERLIA 21119.84 B-201 3 MANISHABEN KAM LESHBHAI MISTRI B-203 53715.2 4 NARENDRA VINODBHAI PANCHAL 62260.8 B-204 5 BHARTI M....
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....IKABEN KANIYALAL PATEL D-104 51 LILABEN PARMAR D-105 41775.776 52 lajanti Mukesh Panchal D-202 35476.448 HARDIKABEN HARDIKKUMAR 39065.6 53 D-203 MEVAOA 54 Vandnaben Kaniyalal Panchal D-204 40286.4 43069.824 55 VINABEN VINODKUMAR PATEL D-205 Page 2 of 10 31496.64 56 KAILASHBEN RAMESHBHAI PATEL D-206 57 Rekhaben Brijeshbhai Prajapati D-301 12208 PALLAVIBEN KAMLESHBHAI 36624 58 D-302 CHOUHAN 41849.024 59 NAYANABEN AND HARDIK ANO HANJA BABUBHAI PRAJ D-303 39993.408 60 ROHIT SHANTILAL PRAJAPTI D-304 45657.92 61 USHABEN AMBALAL VALAND D-305 7130.399808 62 PINKY HARSHADKUMAR PANCHAL D-306 26857.6 63 MEGHA PRIYANKBHAI PANCHAL D-401 37844.8 64 HINABEN PRATIKBHAI BHAVSAR D-402 42605.92 65 TEJAS BHARATBHAI PANCHAL D-403 66 Anandikuar Karansingh Rao D-404 38333.12 42996.576 67 ARTIBEN PRASHANTKUMAR PANDYA D-405 68 RA51LABEN GONOALIYA D-406 26857.6 20265.28 69 RUPALJIGNESH KALARIYA D-501 70 PINAL MEHUL NAYAK D-502 40677.056 41507.2 71 ARUNOHTIBEN PRAVINBHAI DAVE D-503 8933.204 ....
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....115 JAYSHREEBEN JIVIN CHAUHAN F-101 28005.152 116 KOKILABEN VINODBHAI PATEL F-102 26979.68 117 HETALBEN SAMIRBHAI PATEL F-103 118 NAYANABEN PANCHAL F-104 35183.456 27638.912 119 SHAILKUMARI DIGVIJAYSINH THAKUR F-105 8228.192 120 RAGHUNATH RAMCHANDRA BHOSALE F-106 35647.36 121 VIMALKUMAR PURANSINGH F-201 122 GAJRAJ SURESH YADAV 123 VARSHABEN K SHAH 124 VIMALKUMAR K PANCHAL F-202 3369.408 F-203 29299.2 I-502 25636.8 125 KINJALBEN CHETANKUMAR PANCHAL F-205 23195.2 126 JAGJEETA VEERENDRAKUMAR RAJPUT F-206 3418.24 127 DIMPALBEN KAIVALBHAI PATEL F-301 28371.392 128 SHARDABEN RAMESHBHAI PANCHAL F-302 33449.92 129 NITABEN JAGDISHBHAI PANCHAL F-303 130 RANI SAT!SHKUMAR SONI F-304 32668.608 25636.8 131 SITABEN ANILBHAI PANCHAL F-305 28005.152 132 DHARMISHTHABEN PRADIPBHAI MODI F-306 26857.6 133 KAILAASH BHARATBHAI PATEL F-401 28566.72 134 HETALBEN ANILKUMAR PATEL F-402 135 RAMESHBHAI G PATEL F-403 28078.4 26857.6 136 VAISHALIBEN KIRAN PANCHAL F-404 28078.4 137 PIYUSHKUMAR NATVARLAL PANCHAL F-40....
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X X X X Extracts X X X X
....EL H-201 32961.6 32961.6 185 JAMUBEN JIVANBHAI PATEL H-202 186 MOULESH J DARJI H-203 * 29299.2 187 DARSHNABEN OIPAK RAMI H-204 188 OILIPKUMAR LALUBHAI KALAL H-301 189 Archana M Panchal H-302 34182.4 PRAVINCHANDRA VIASANTLAL 29299.2 190 H-303 TRIVEDI 29299.2 191 KHUSHABU RAJAN TRIVEDI H-304 34182.4 192 NIRMALABEN BHARATBHAI PRAJAPTI H-401 193 MEENABEN J PANCHAL H-402 * 27028.512 194 TARABEN JAYANTIBHAI PANCHAL G-503 25636.8 195 REKHABEN RAMESHBHAI PANCHAL H-404 CHANORIKABEN HASMUKHBHAf 25636.8 196 H-501 BKALAL 197 MEENABEN DIPAKKUMAR PAIEL H-502 kud 198 NARANBHAIMAICWANA H-503 * Page 7 of 10 25636.8 199 ANKITABEN VISHALBHAI H SLITHAR H-504 31691.968 200 KINJALBEN SUNILKUMAR PATEL H-601 23073.12 201 DAKSHABEN PRAKASHBHAI MISTRY H-602 * 202 PARESHKUMAR M VADHAVANA H-603 31765.216 203 MANJULA DHURALAL PANCHAL H-604 3479.28 204 HEMAXIHARSHADBHAIPATEL H-701 30544.416 205 URMILABEN VIPULBHAI PANCHAL H-702 29299.2 206 MUKTABEN B BARVADIYA H-703 207 LABHUBEN RATHOD H-70....