TaxTMI 
TaxTMI 
2022 (8) TMI 362
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....stigation in respect of an application dated 25.07.2019, filed by the Applicant No. 1 under Rule 128 of the Rules, alleging profiteering in respect of construction service supplied by the Respondent. The Applicant No. 1 had submitted that she had booked a Flat No. C-701 in the Respondent's project "MJR Clique Hydra" Electronic City Phase-I. Bengaluru and had alleged that the Respondent had not passed on the benefit of Input Tax Credit (ITC) to her by way of commensurate reduction in price. The DGAP has intimated that the Applicant No. 1 had lodged the complaint with the Karnataka State Screening Committee. Thereafter, the above reference was examined by the Standing Committee on Anti-profiteering, in its meeting held on whereby it decided to forward the same to the DGAP to conduct a detailed investigation in the matter. ii. The Applicant No. 1 had submitted the following documents along with her application:- (a) Scanned Copy of proof of Identity. (b) Sale Agreement. (c) Construction Agreement. (d) Break up of cost as given by the Respondent. (e) Demand notes from level foundation to 14th floor, internal plastering and final....
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....19, 15.01.2020, 13.02.2020 and 08.05.2020, had submitted the following documents/information vide his letters/e-mails dated 02.12.2019, 05.12.2019, 16.01.2020, 14.02.2019, 26.02.2019, 16.05.2020 and 23.05.2020:- (a) Copies of GSTR-1 returns for the period July, 2017 to September, 2019. (b) Copies of GSTR-3B returns for the period July, 2017 to September, 2019. (e) Copies of Tran-1 filed. (d) Electronic Credit Ledger for the period July, 2017 to September, 2019. (e) Copies of VAT & ST-3 returns for the period April, 2016 to June, 2017. (f) Copies of all demand letters, sale agreement/contract issued in the name of the Applicants. (g) Details of applicable tax rates, pre-GST and post-GST. (h) Copy of Balance Sheet and Cost Audit Report for F.Y. 2016-17, and 2017-18. (i) Details of VAT, Service Tax, ITC of VAT, Cenvat Credit for the period April, 2016 to June, 2017, Output GST and ITC for the period July, 2017 to June, 2019 for the Project "MJR Clique Hydra". (j) Cenvat/Input Tax Credit Ledger for the F.Y. 2016-17, 2017-18 and 2018-19 reconciled with VAT, ST-3 and GSTR-3B returns. (k) Li....
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....h Slab Floor 4% 187994 12 On Completion or Eighth Slab Floor 4% 187994 13 On Completion of Nineth Slab Floor 4% 187994 14 On Completion of Tenth Slab Floor 4% 187994 15 On Completion of Eleventh Slab Floor 4% 187994 16 On Completion of Twelfth Slab Floor 4% 187994 17 On Completion Thirteenth Slab Floor 4% 187994 18 On Completion of Fourteen Slab Floor 4% 187994 19 On Completion of Internal Plastering 5% 234993 20 On Registration 5% 234993 TOTAL (A) 100% 46,99,853 OTIIER CHARGES (Approx.). 1 **Registration and stamp Duty 109303 2 *BWSSB and BESCOM charges and deposits 204750 3 Maintenance fee 84240 4 Service tax on Maintenance fee 10412 5 Professional charges 30000 6 Club charges 150000 TOTAL (B) 588705 GRAND TOTAL (A+B) 52,88,558 ix. Para 5 of Schedule-III of the CGST Act, 2017 (Activities or Transactions which should be treated neither as a suppl....
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....her mentioned that prior to 01.07.2017. deduction from turnover of the payments made to the registered contractors and sub-contractors (from the taxable turnover under VAT) on which VAT @ 4% was being levied. Further, post-GST, the Respondent could avail the ITC of GST paid on all the inputs and input services including the sub-contracts. The DGAP has also observed from the information submitted by the Respondent for the period April, 2016 to September, 2019, the details or the input tax credits availed by him. his total turnovers from the project "MJR Clique Hydra", the ratios of ITCs to the turnovers during the pre-GST (April, 2016 to June, 2017) and post-GST (July, 2017 to September, 2019) periods, have been furnished in Table-'B' given below:- Table 'B' (Amount in Rs.) S.No. Particulars (Pre-GST) (Post-GST) 1 Credit of Service Tax Paid on Input Services (A) 70,59,822 2 Input Tax Credit of VAT paid on Inputs (B) 1,07,27,831 3 Total CENVAT/VAT/Input Tax Credit Available (C=A +B) 1,77,87,653 4 Input Tax Credit of GST Availed (D) 3,81,52,051 5 Total Turnover from Resi....
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....nbsp; 8,94,35,880 8 Total Net Basic Demand during, 2017 to September, 2019 G 19,03,70,048.00 9 GST @12% H=G*12% 2,28,44,405.76 10 Total demand I=G+H 2,32,44,14,453.76 11 Recalibrated Basic Price J=G*(1-D) or 94.95% of G 18,07,56,360.58 12 GST @ 12% K=J*12% 2,16,90,763.27 13 Commensurate demand price L=J+K 20,24,47,123.85 14 Excess Collection of Demand or Profiteered Amount L=I-L 1,07,67,329.91 xv. DGAP has claimed from Table-'C' above that the additional input tax credit of 5.05% of the turnover should have resulted in commensurate reduction in the basic prices as well as cum-tax prices. Therefore. in terms of Section 171 of the CGST Act, 2017. the benefit of additional ITC should have been passed on by the Respondent to the recipients. In Other words, by not reducing the pre-GST basic prices by 5.05% on account of additional benefit of ITC and charging GST @ 12% on the pre-GST basic prices, the Respondent has contravened the provisions of Section 171 of the CGST Act, 2017. xvi. On the basis of the afo....
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....f additional ITC of 5.05% of the turnover had accrued to the Respondent for the project "MJR Clique Hydra". This benefit was required to be passed on to the recipients but this was not done. Therefore, Section 171 of the CGST Act, 2017 has been contravened by the Respondent, inasmuch as the additional benefit of ITC @ 5.05% of the base prices received by the Respondent during the period 01.07.2017 to 30.09.2019, has not been passed on by the Respondent to 190 recipients including the Applicant No. 1. These recipients were identifiable as per the documents provided by the Respondent, giving the names and addresses along with Unit Nos. allotted to such recipients. Therefore, the total additional amount of Rs.1,07,67330 /- (Rupees One Crore Seven Lakh Sixty Seven Thousand Three Hundred and Thirty only) was required to be returned to the Applicant No. 1 and such eligible recipients. The DGAP has also stated that the Respondent has supplied construction services in the State of Karnataka only. The DGAP has further reported that, the present investigation covered the period from 01.07.2017 to 30.09.2019 and profiteering, if any, for the period post September, 2019, had not been examined ....
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....mained unsold as on September 2019 1,10,960 5. Total 3,45,690 ii. The VAT Input Tax Credit and CENVAT Credit for the period 2016-17 and April 2017 to June 2017 was Rs.1,77,87,653/-. iii. amount of Input Tax Credit of GST availed during the period post GST was Rs.3,81,52,051/-. This credit included Rs.35,26,800/- of ITC relating to unregistered supplies paid under RCM which was not liable to be paid pre-GST. iv. As far as the benefit of input tax Credit was concerned, the basic prices post-GST got increased and were not decreased after introduction of GST and therefore no additional benefit accrued to him. Further Since most of his purchases were from dealers and not manufacturers, there was no credit which he had foregone pre-GST but subsequently got benefit of the same. Instead there was increase in the GST rates on the inputs and input services for which he had paid extra. The additional credit of GST in quantum availed by him was additionally paid by him either due to increase in tax rate, or increase in cost of goods and services. Thereby, the Respondent has stated that no additional benefit accrued to him. Accordingly no benefit was passe....
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....mstances to make excessive profits; Law Lexicon - To Seek or obtain excessive profits, one who was given to make excessive profits: Shorter Oxford Dictionary - Make or seek to make an excessive profit; To seek or obtain excessive profits especially illegally x. Whereas the Report or DGAP did not bring out any of these factors, to establish that there was a benefit, which was accrued which otherwise would have not accrued to the Respondent. The Respondent has also submitted that the DGAP has made certain assumptions and presumptions to determine the profiteering, if any, whereas as per the methodology and understanding of the Respondent. the basis and methodology should be different. xi. The methodology adopted in the DGAP's Report for ascertaining the increase in input credit Was not acceptable for the following reasons:- a) The availment of Input Tax Credit/CENVAT Credit was essentially linked to the expenditure incurred or to be incurred and not linked to the revenue. Adopting the percentage of credit to revenue without considering the expenditure incurred was improper. Example, with total realizable value of Rs.1,000/- an....
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.... credit available of the taxes extra paid could not be considered to be benefit of input tax. In other words, if there was no reduction in basic price compared to the pre-GST. the amount of tax was paid extra and the extra paid tax was being taken as credit. Hence, the same could not be considered as benefit or input tax credit which has been explained with the following example:- Sl. No. Details Item 1 Item 2 Item 3 1 Pre- GST Basic Cost 100 100 100 2 VAT 14.5 14.5 14.5 3 Taxes Paid 14.50 14.50 14.50 4 ITC availed 14.50 14.50 14.50 5 Post GST Cost 120 100 90 6 GST 21.6 18 16.2 7 Taxes Paid 21.60 18.00 16.20 8 ITC availed 21.60 18.00 16.20 9 Increase in tax payment 7.10 3.50 1.70 10 Increase in ITC 7.10 3.50 1.70 11 Excess Benefit 0.00 0.00 0.00 xii. Therefore, the Respondent has objected to the methodology adopted in the Report as the Table-B Of the DGAP's Report determined the percentage of excess ITC to turnover. On account of which he has the following objections:- a. The computa....
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....t of time and also taking into consideration the revised costs of the project net of GST credits. Therefore, to arrive at the value at Sl. No. 8, the reduction should have been made as to the collection pertaining to post-GST bookings. The amount of revenue relatable to flats booked post-GST was Rs.11,07,52,014/-. After reducing the same the amount at Sl. No. 8 would have been Rs.9,86,99,963/-. c) Further, also the Sl. No. 10 was computed including the GST charged to the customers. Since the entire amount collected was remitted to Government, even if there was excess. the same should be claimed as refund by the buyers and it could not be asked to be paid by the Respondent again as the same amount was not at all retained. It not what should have been done, instead what was benefitted has to be seen. Since no benefit had accrued and retained by the Respondent in this regard, addition of the output GST again over and above the ITC benefit was not proper. d) Giving effect to this value, and adopting the revised increase in credit as mentioned above, the revised amount at Sl. No. 14 would be Rs.46,09,683/-, as per the revised computation given in Annexure-I. x....
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....erms of Section 171 of GST Act, 2017. d) The application filed by the Applicant No. 1 was proper and in pursuance of the same the profiteering computed in the present case was correct in terms of Section 171 of the CGST Act. 2017. e) As per Rule 126 of the CGST Rules, 2017, this Authority has been empowered to determine the methodology and procedure for determination as to whether the reduction in the rate of tax or the benefit of ITC has been passed on by the registered person to the recipients by way of commensurate reduction in prices. This Authority in exercise of power delegated to it under the Rule 126 has notified the Methodology & Procedure vide Notification dated 28.03.2018 which was also available on the website. However, it was submitted that no fixed/uniform mathematical methodology can be determined for all the cases of profiteering as the facts and circumstances of each ease as well as the nature of goods or services supplied in each case differ. Therefore, the determination of the profiteered amount has to be computed by taking into account the particular facts of each case. The computation of commensurate reduction in prices Was purely a mathematic....
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....ately under Section 171 as it itself prescribed such methodology and procedure. Therefore, the facts of the case in the case law referred were different from those of the present case. i) The legislature had delegated the task of prescribing the powers and functions of the Authority to the Central Government as per Section 171 of CGST Act, 2017 read with Section 2 (87) of the Act, on the recommendation of the GST Council. The Central Government, on the recommendation of the GST Council, which was a constitutional Federal Body under 101th Amendment or the constitution, has formulated and notified Rule 126, 127 and 133. which prescribed the functions. duties and powers of the Authority. All Rules of Anti-profiteering have been framed under Section 164 of the CGST Act, 2017 which has the sanction of the Parliament and the State Legislatures. It also showed that the delegated power to the Authority given under Section 171 (3) of the said Act has been duly exercised by the Central Government by formulating the Rules, on the recommendation of the GST Council. Therefore, the powers to determine its own methodology under Rule 126 was justified and enabled this Authority to clarify....
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....would not have accrued to the Respondent. k) The entire Report dated 01.06.2020 was completely based on the information/data provided by the Respondent and no assumptions and presumptions have been trade. l) The ITC was available on the inputs (goods and services) purchased/used in the project, which was a cost to the Respondent. Hence, when ITC was being considered in the investigation then it implied that the cost/expenditure to the Respondent has been considered. The DGAP has also stated that Section 171(1) of the CGST Act, 2017 was very clear which Stated that any reduction in the rate of tax or the benefit of ITC has to be passed on to the recipient by way of commensurate reduction in price. Therefore. the benefit of ITC was to be passed on to each recipient or to flat buyers in the present ease. Now, if output taxable turnover was not considered in the investigation then it would be difficult to ascertain that out of total benefit of ITC accrued to the Respondent in the GST period, what amount of benefit was to be passed on to which recipient or flat buyer. Since each recipient was eligible to get his/her due benefit in terms of above Section. the output tax....
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....egime. Therefore, the basic price of the flats was arrived by the Respondent only after due consideration or all the expenses and non-creditable costs. Most of these non-creditable costs were related to non-availability of ITC of Central Excise Duty paid on inputs and other such costs. In GST regime from 01.07.2017 onwards, the credit of such non-creditable costs became creditable or in other words, the ITC of GST paid on all goods and services was available to the Respondent for payment of his GST liabilities. n) The sale of land being a transfer of immovable property was outside the ambit of both Service Tax as well as GST. There was no implication of the cost of land in arriving at the ratio of total credit available to the Respondent, as abatement for the same was provided in determination of taxable turnover. Further, cost of land and construction cost were integral parts of the cost of project and were already accounted for in the turnover i.e. demands made from the flat buyers which has no relevance whatsoever in determination of the benefit of the additional ITC that accrued to a supplier (the Respondent) due to implementation of GST, which was required to be passe....
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....mounts raised post obtaining completion certificate have been included in terms of Para of the Schedule III, read with clause (b) of Para 5 of the Schedule II of the CGST Act, 2017. r) The amounts pertaining to the flats booked after obtaining completion certificate did not attract GST in terms of Para 5 of the Schedule III of the CGST Act. 2017. However, the amount pertaining to the flats booked post GST prior to obtaining completion certificate, were required to be considered as such home buyers were also eligible to get their due benefit of the ITC from the Respondent. s) The price included both the basic price and the tax charged on it. Therefore, any excess amount collected from recipients, even in the form of tax in excess of what was to be legally collected, must be returned to the recipients. By not reducing the basic prices commensurately in terms of Section 171 of the CGST Act, 2017, the Respondent forced his customers/flat buyers to pay extra tax which they were not liable to pay. Therefore, it was clear that the amount of extra tax (GST) on the increased basic price was the amount paid by the flat buyers which they were not supposed to pay. If any supp....
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.... not bearing any extra burden of the tax. but only making payment of lax to the Government exchequer on the supplies received directly. Otherwise, if the supplier was registered, the Respondent would have paid the amount or tax to the supplier and the supplier would have deposited the same with the Govt. Furthermore, the DGAP has mentioned that in pre-GST regime, though the tax component was included in the prices of supplies received by the Respondent from the unregistered person/dealer but CENVAT/ITC was not available to the Respondent for the same, whereas in GST regime, since the Respondent was paying GST under RCM, the same was available to the Respondent as ITC. v) Illustrated how the benefit of ITC in GST regime was available to a registered person in continuation of his earlier reply dated 10.09.2020. Though, the DGAP's investigation has not examined the cost components specifically Central Excise Duty, but same was equally applicable to the Respondent irrespective of his purchases from Dealers or Manufacturers. The Central Excise Duty was included in the cost of goods like Steel, Cement etc. purchased by the Respondent in pre-GST period from Dealers. Moreover,....
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....quer. But this amount of tax was being paid by the Respondent by utilizing the ITC (96% approx.) and merely 4% by Cash. Hence. most of the part of the amount collected from the customers in the form of cash in lieu of GST was being retained by the Respondent. Further, large portion of this ITC being utilized by the Respondent for the payment of GST to the Government exchequer was the ITC which was not available to him in pre-GST regime. Hence, the Respondent has benefitted with this additional ITC in post-GST regime which was required to be passed on to the recipients/customers in terms of Section 171 (1) of the CGST Act, 2017. Moreover, any increase in tax component was charged to and collected from Customers, whereas any increase in the quantum of ITC might be pocketed. z) The Respondent has ingeniously not considered the Service Tax in the pre-GST period and is merely taking the VAT component, hence comparison made by the Respondent was not correct. The anti-profiteering measures provided under Section 171 of the CGST Act, 2017 were entirely based on the CGST Act, 2017 and all the provisions of the above Act were applicable to anti-profiteering also. The DGAP has furthe....
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....n in the value etc. also need to be addressed by the Authority. 8. On the issue of reduction in the tax rate. it is apparent from the DGAP's Report that there has been no reduction in the rate of tax in the post GST period; hence the other issue to be examined is as to whether there was any net benefit of ITC with the introduction of GST, which could have been transferred to recipients. (a) On this issue it has been reported by the DGAP, as tabulated above, 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 3.71% and during the post-GST period (July-2017 to September2019), it was 8.76%. Hence, according to the DGAP, post-GST, the Respondent has been benefited from additional ITC to the tune of 5.05% (8.76%-3.71%) of his turnover and the same was required to be passed on to the Applicant No. 1 and the other customers/ flat buyers/ recipients. Therefore, the amount of ITC benefit to be passed on to all the customers/ flat buyers/ recipients is Rs.1,07,67,330/-. (b) However, the Respondent has questioned the above methodology adopted by the DGAP in computing the benefit of i....
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....e extent or benefit to be passed on by way of reduction in the price which has to be computed in respect of each product or unit or service based on the price and the rate of tax reduction or the additional ITC which has become available to a registered person. (g) The legislature has deliberately not used the word 'equal' or 'equivalent' in this Section and used the word 'Commensurate' as it had no intention that it Should be used to denote proportionality and adequacy. The benefit of additional ITC would depend on the comparison of the ITC/CENVAT credit which was available to a builder in the pre-GST period with the ITC available to him in the post GST period w.e.f. 01.07.2017. (h) Similarly, the benefit of tax reduction would depend upon the pre rate reduction price of the product and quantum of reduction in the rate of tax from the date of its notification. Computation of commensurate reduction in prices is purely a mathematical exercise which is based upon the above parameters and hence it would vary from product to product or unit to unit or service to service and hence no fixed mathematical methodology can be prescribed to determine the amount of be....
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.... mandatory and legally enforceable. (n) It is abundantly clear from the above narration of the facts and the law that no elaborate mathematical calculations are required to be prescribed separately for passing on the benefit of ITC and computation the profiteered amount. (o) The Respondent cannot deny the benefit or ITC to his customers on the above ground and enrich himself at the expense of his buyers as Section 171 provides clear cut methodology and procedure to compute the benefit of ITC and the profiteered amount and he is well aware of the benefit or additional ITC which he has obtained post-GST. In view of the above said submissions, the Authority finds that the contention of the Respondent regarding absence of methodology is untenable and hence rejected. 9. The Respondent has alleged that Section 171 of the CGST Act, 2017 is ultra vires of the constitution and thus, investigation should be either dropped or kept in abeyance till the constitutional validity was being scrutinised by the Hon'ble High Court. (a) In this connection it would be appropriate to mention that this Authority has not acted in any way as price controller or reg....
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....tion given by the Respondent is untenable. 10. The Respondent has mentioned the Apex Court's judgement passed in the case of CIT v. B. C. Srinivasa Setty- (1981) 2 SCC 460 in support of his argument. Careful perusal of this judgement shows that it involved valuation of the goodwill for computation of income tax which is not the issue in the present case. The Respondent has also cited the judgement passed in the case or Commissioner of C. Ex. & Cus., Kerala vs Larsen & Toubro Ltd. 2015 (039) STR 0913 (S.C.) in which the issue involved, is the levy or Service Tax on the indivisible works contracts which is not the matter in the present case. Therefore the above cases have no relevance in the facts of the present case. 11. Respondent has claimed that the availment of Input Tax Credit/CENVAT Credit was essentially linked to the expenditure incurred or to be incurred and not linked to the revenue. Adopting the percentage of credit to revenue without considering the expenditure incurred was improper. This Authority finds that the DGAP has rightly considered the revenue related to flats from homebuyers' list submitted by the Respondent himself wherein the Respondent has recei....
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....d became eligible to avail ITC of the same which was not available to him in pre-GST regime. Hence, now more benefit or ITC has accrued to him. Hence this this Authority finds no merit in this plea of the Respondent. 14. The Respondent has claimed that even in the computation made by the DGAP, the area booked pre-GST was taken as sq. ft. whereas actual sq. ft. as per computation was sq. ft. The Authority finds that, it is evident from the home buyers' list, as submitted by the Respondent himself, that the DGAP has correctly considered the actual area sold in pre-GST regime i.e., prior to 01.07.2017 as sq. ft. which was relied upon while carrying out the investigation. Hence, the above claim of the Respondent is not tenable as it is contrary to the records submitted by the Respondent himself. 15. The Respondent has contended that the DGAP in his computation has only considered the value of revenue received only and not revenue accrued, yet to be received. This Authority notes that the DGAP has correctly considered the value at Sl. No. 5 or Table B above as Rs.27,98,05,928/- as post-GST revenue. This amount has been taken from the home buyers' list submitted by the Re....
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.... This Authority finds that this contention raised by the Respondent is not correct as the Respondent has not only collected excess base price from the customers (which they were not required to pay due to the availability of ITC to the Respondent) but he has also compelled them to pay additional GST on such excess base price which they should not have paid. By doing so the Respondent has defeated the very objective of both the Central as well as the State Governments which aimed to provide the benefit of ITC to the general public. The Respondent was legally not required to collect the excess GST and therefore. he has not only violated the provisions of the CGST Act, 2017 but has also acted in contravention of the provisions of Section 171 (1) of the above Act as he has denied the benefit of ITC to his customers by charging excess GST. Had the Respondent not charged the excess GST, the customers would have paid less price while purchasing the flats from the Respondent and hence the above amount has rightly been included in the profiteered amount as it denotes the amount of benefit denied by the Respondent to his recipients. Therefore. this Authority finds that the above co....
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....his amount is inclusive of Rs.1,03,453/- (including GST on the base amount of Rs. 92,369/-) which is the profiteered amount in respect of the Applicant No. 1, mentioned at serial No. 108 of Annexure-13 of the said Report. 21. For the reasons mentioned above, the Authority determines the profiteered amount for the period from to 30.09.2019. in the instant case. as Rs. Rs.1,07,67,330/- for the project 'MJR Clique Hydra'. This profiteered amount of Rs. Rs.1,07,67,330/- includes GST on the base profiteered amount of Rs.96,13,687/-. The homebuyer/customer /recipient and unit No. wise break-up of this amount as given in Annexure-13 of the DGAP Report is accepted. This amount is inclusive of Rs.1,03,453/- (including GST on the base amount of Rs. 92,369/-) which is the profiteered amount in respect of the Applicant No. 1, mentioned at serial No. 108 of Annexure-13 of the said Report. 22. 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 customers/flat buyers/recipients commensurate with the benefit of ITC received by him as has been detailed above. 23. The Respondent is als....
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....lique Hercules under the same registration in Bengaluru in respect of which the DGAP has not conducted any investigation to ascertain whether the Respondent is liable to pass on the benefit ITC to the recipients of these projects or not. Since the execution of the above projects has been admitted by the Respondent himself, therefore, there are Sufficient reasons to believe that the Respondent may be liable to pass on the above benefits as per the provisions of Section 171 (1), Further, the Respondent also has a Single GST registration arid is maintaining a joint ITC Register and is availing ITC on all the projects which he is executing from a common pool of ITC, to discharge his GST output liability on these projects through the combined GSTR-3B Returns. Therefore, all the projects on which the Respondent is availing ITC from the common pool are required to be investigated to determine whether he has passed on the benefit of ITC to the buyers of each project, which is being executed by him. Accordingly. The Authority, as per the Rule 133 (5) (a) or the CGST Rules, 2017, directs the DGAP to investigate all the other projects of the Respondent including those specifically mentione....
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....ings. " Further, the Hon'ble Supreme Court, vide its subsequent Order dated 10.01.2022 has extended the period(s) 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 gland excluded for the purposes of limitation may he 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 of the CGST Rules, 2017. 32. A copy of this order be supplied to all the parties and file of the case be consigned after Completion. A copy each of this order be sent, free of cost, to the Applicant No. 1, the DGAP, the Respondent, Commissioners CGST/SGST Karnataka, the Principal Secretary (Town and Country Planning), Government of Karnataka as well as Karnataka RERA for necessary action. Annexed: Annexure A in Pages 1 to 4 ============= Document 1 SI. Name of Customer No ANNEXURE-A LIST OF HOMEBU....
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....14,772 50 Mr. B Vijayaraghavan 8304 13,250 51 Mr. Ajithkumar PV B401 15,218 52 Mrs. Neetha Dinesh Kamath B402 12,163 53 Mrs. Sneha Das Gupta B403 12,245 54 Mr. Padma Raja P B404 13,435 55 Mr. Amit Saurabh 8501 11,730 56 Mr. Sunayana Menon B502 25,844 Page 1 of 4 57 Mr. Harish R B503 9,774 58 Mr. Kiran Kumar M 8504 18,677 59 Mrs. Divya Singh B601 11,813 60 Mr. Prashant Tandon B602 12,013 61 Mr. Nitish Narayanan 8603 12,000 62 Mr. Srinivasa Rao 8604 13,984 63 Mrs. Radhika Velaparthi 8701 2,50,489 64 Mrs. Amrita Kumari 8703 17,782 65 Mr. V Sanjeev Raman 8704 13,505 66 Mr. Milan Satpathy 8801 9,153 67 Mr. Abhishek Ghutak B802 0 68 Mr. Arun Chandra Pandey B803 11,434 69 Mr. Prashant Singh B804 14,365 70 Mr. Nagarjuna Reddy KR B901 55,860 71 Ms. Lipi Dash B902 12,363 72 Mr. Pooja Thakur B903 12,082 73 Mrs. Shriya Mahato 8904 13,968 74 Mr. Santhosh Kumar K B1001 12,496 75 Mr. Jithin Ra....
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.... C1201 12,829 127 Mr. Anil Gopal Kotian C1202 0 128 Mr. Vishwanath Porwal C1203 0 129 Mr. Siddharth Hazarika C1204 15,060 130 Mr.Priyabrata Dash C1301 19,637 131 Mrs. Kanika C1302 0 132 Mr. Vinay Menon S C1303 0 133 Mr. Umang Trivedi C1304 0 134 Mrs. Jeyanthi P 61401 0 135 Mr. Ravi Kumar DE 61404 0 136 Ms. Ramya Rajan D201 0 137 Mr. Rajiv Sonowal D204 1,01,129 138 Mr. Amarjyoti Borah D301 2,55,585 139 Mr. Bikram Kumar Mallick D303 23,902 140 Mr. Shankar B D304 28,302 141 Mr. Vijay Kumar PV D401 12,197 142 Mr. Pronce Jenifer D402 0 143 Mr. Debojyoti Hazra D403 69,414 144 Mr. Sarad Patel D404 69,894 145 Mr. Chetan R Kumar D501 24,282 146 Mr. Mohamed Abdul Sattar D503 24,891 147 Mr. Animesh Kumar Jha D504 27,946 148 Mr. Narayan C D601 0 149 Mrs. Kauser Shahla D603 15,100 150 Mrs. Mahzeeba Afreen D604 25,727 151 Mr. Bharat C D701 25,332 152 Mr. Deepesh Jain D703 21,328 153....