TaxTMI 
TaxTMI 
2022 (8) TMI 687
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....putation done in Investigation Report dated 28.08.2020 of the DGAP. Such computation in Investigation Report dated 28.08.2020 of the DGAP was not contested by the Respondent. The Respondent has also not contested the said Internal Order No. 01/2021 dated 16.03.2021 of this Authority. The total profiteered amount calculated in such Investigation Report dated 28.08.2020 of the DGAP and Interim Order of this Authority was Rs.7,90,95,474/-(i.e. Rs. 7,06,20,959/- + Rs. 84,74,515/- i.e. GST thereon). 3. The brief facts of the case are that the DGAP had submitted an Investigation Report dated 28.08.2020 before this Authority in the case of the Respondent. This Authority, vide Order No. 01/2021 dated 16.03.2021 referred the matter back to the DGAP to reinvestigate the case on the following issues:- a. The Respondent's claim of having passed on the benefit of ITC of Rs. 8,28,91,520/- was required to be verified against third party evidence in the form of written acknowledgment receipts from the home buyers evidencing the receipt of ITC benefit, including the quantum and also evidencing that the said benefit was passed on in terms of Section 171 of the CGST Act, 2017. For this, a....
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....in terms of Section 171 (1) of the CGST Act, 2017 which states that "Any reduction in the 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". Needles to state that the claim made by the Respondent of having passed on the benefit has to be supported by acknowledgements which the Respondent shall procure from the homebuyers alongwith their contact details i.e. e-mail & Phone/Mobile No., failing which his claim will have to be considered as not established. The Respondent shall submit the homebuyer wise evidence, as detailed above within a period of 30 days of this Order and the same shall then be verified by the DGAP. Accordingly, the matter is sent back to the DGAP for further investigation as per the provisions Section 171(2) of the CGST Act, 2017 read with Rule 133(4) of the CGST Rules 2017. This Authority directs the DGAP to verify the evidence submitted by the Respondent to evidence the passage of ITC benefit from the Respondent to the homebuyers and submit his Report, alongwith all the relied upon documents/evidence. The DGAP is accordingly directed to re-investigate t....
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.... The period covered by the current reinvestigation is the same as covered in Investigation Report dated 28.08.2020 i.e., from 01.07.2017 to 30.09.2019. h. As directed by this Authority in I.O. No. 01 of 2021 dated 16.03.2021, all the issues as mentioned above, had ban duly covered in this report within the confines of the data/information supplied by the Respondent and home buyers. i. The time limit to complete the investigation was 21.09.2021 in terms of Rule 129(6) of the Rules However, due to force majeure caused in the light of Covid-19 pandemic, the investigation could not be completed on or before the above date. Further, Hon'ble Supreme Court of India passed an Order dated 08.03.2021 in Suo Motu Writ Petition (Civil) No. 3 of 2020, wherein, it was stated that "in cases where the limitation would had expired during the period between 15.03.2020 till 14.03.2021, notwithstanding the actual balance period of limitation remaining, all persons shall had a limitation period of 90 days from 15.03.2021. In the event the actual balance period of limitation remaining, with effect from 15.03.2021, is greater than 90 days, that longer period shall apply". The above reli....
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....e Respondent submitted the following documents/information: (i) Copies of confirmation (e-mails) from 4 customers acknowledging the receipt of input tax credit (ii) Certificate from Chartered Accountant certifying the total amount of input tax benefit received by the Respondent and passed on to the customers along with applicable interest (iii) E-mail Ids of 174 home buyers. l. As per the directions of this Authority vide I.0. No. 01/2021 dated 16.03.2021, the DGAP initiated re-investigation of the case. At the time of submission of earlier investigation report dated 23.08.2020. the Respondent had submitted the copies of Credit Notes, Ledgers, Customer's communication letter and Customers Master List only which were found insufficient by the Authority to corroborate his claim of having been passed on the benefit of ITC. Accordingly, during the reinvestigation, vide letter dated 31.05.2021, the Respondent was requested to provide the contact details i.e., e-mail and Phone/Mobile Nos. of the home buyers and details of payments of ITC benefit and applicable interest along with documentary evidences as per the directions contained in the aforesaid or....
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....s. Furthermore, the Respondent had also claimed that the 'Prestige Lake Ridge' project had been completed and the possession had been handed over to the home buyers of the project. Hence, the Respondent had showed his inability in procuring acknowledgments/receipts and contact details from the home buyers. However, the Respondent had provided the Chartered Accountant's Certificate as third-party verification certificate, certifying his claim of having been passed on the benefit of ITC (GST) of Rs.8,28,91,520/- along with interest @18%. n. Further, it was observed that out of the 454 home buyers, profiteering of Rs.7,90,95,474/- was computed in respect of 452 home buyers (As reported in Pant 27 of the Investigation Report dated 28.08.2021) only. In respect of remaining two home buyers, no profiteering could be computed as no demands were raised from these two home buyers in post-GST period. However, out of these two, the Respondent had claimed to be passed on an amount of Rs.6,482/ to one home buyer. Further, the Respondent had provided the email ids of 174 (including Applicant No. 1) home buyers only. In order to verify the claim of the Respondent, c-mails were sent to the....
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.... profiteering computed but claimed to be passed or Mail sent but no reply received. 6. Other than Applicant 7 4,58,670 8,02,275 0 -3,43,605 Emails were sent but no reply received. Even if, the Respondent passed the benefit, the excess benefit passed cannot be appropriated with other buyers. 7. Other than Applicant 132 1,89,69,934 1,45,95,940 0 43,73,994 Emails were sent but no reply received. Even if, the Respondent passed the benefit, Respondent is still required to pass on the differential amount. Sub Total (Not replied) III=5+6+7 140 1,94,28,604 1,54,04,697 0 43,73,994 Buyers to whom emails were sent but no reply received. Sub Total (Emailed) IV=II+III 173 2,43,41,094 1,92,80,565 36,84,259 54,50,378 All the buyers to whom emails were sent. 8. Other than Applicant 1 0 0 0 0 No profiteering computed Emails id provided but no mail was sent. 9. Other than Applicant 188 3,28,27,071 4,34,39,705 0 -1,06,12,634 Emails ids were not provided. Emails could not be sent. Even if, the Respondent passed the benefit, the excess benefit passed cannot be approp....
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....pondent also not provided the details required for computation of interest amount i.e., amounts raised to home buyers along with his dates, amounts received from the home buyers along with date of receipt. In absence of these details, the computation of the interest @18% and necessary verification thereof could not be done by the DGAP. Furthermore, as the benefit of ITC of GST claimed to had been passed on by the Respondent could not be verified fully, the necessary verification of claim of the Respondent of having passed on the interest amount also could not be done. p. On the basis of aforesaid discussions and findings it was concluded that in the initial investigation Report dated 28.08.2020, the profiteered amount was computed as Rs.7,90,95,474/- in respect of 452 home buyers. The Respondent claimed to had already passed on the ITC benefit of Rs.8,28,91,520/- to all the home buyers. However, the Authority did not consider the Respondent's claim and vide Interim Order 01/2021 dated 16.03.2021, directed the Respondent to procure the acknowledgement receipts from all the home buyers and also provide the contact details of all the home buyers to the DGAP for further verifi....
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....a entails, 142 had not responded. Therefore, as stated in above pares, the Respondent is required to pass on the benefit of profiteered amount on account of additional ITC to the tune of Rs.7,54,50,978/- to 450 home buyers. 5. The above Report dated 18.11.2021 was carefully considered by this Authority. Since, the quorum of the Authority of minimum three Members, as provided under Rule 134 was not available till 23.02.2022, the matter was not decided. With the joining of two new Technical Members in February 2022, the quorum of the Authority was restored from 23.2.2022 and a Notice dated 25.02.2022 was issued to the Respondent to explain why the Report dated 18.11.2021 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 written submissions, which had been filed on 05.04.2022 wherein the Respondent had, inter-alia submitted following:- a. He had sent communications as early as October 2017 to the Customers of 'Prestige Lake Ridge' stating that the effective prices had reduced since the implementation of GST in India. The factors on the basis ....
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....ITC were also enclosed. e. Based on the above, the provisions of section 171 of the CGST Act, 2017 would have been contravened, had the Respondent not passed on the benefit of the GST ITC to his Customers. As stated above, the Respondent had actually passed on an extra amount of Rs. 37,96,045/- to his customers. Therefore, the allegations that the Respondent had contravened the provision of section 171 of the CGST Act, 2017 are not sustainable in view of the fact that the benefit of ITC received by the Respondent had already been passed on to all his Customers. f. He had passed on the benefit of ITC amounting to 1,78,251/-to the Applicant No. 1, Mr. Deepak Naik V as well. Copy of confirmation received from Mr. Deepak Naik V evidencing receipt of benefit of ITC was enclosed. g. Being a part of a large public group of Companies and always being compliant with various Central and State laws, the Respondent had ensured that it had lawfully complied with all the taxation laws as well. h. The Respondent is customer friendly, part of large public Group of Companies in India and the intention had always been to pass on the accurate amount of savings to h....
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.... Credit Notes, Customers Account Ledger in support of the claim of having been passed on the due benefit to all the customers. l. To further substantiate the fact of having been passed on the ITC benefit and as directed by this Authority vide I.O. dated 16.03.2021 to obtain a thud-party verification certificate validating the claim of the Respondent, the Respondent had also obtained a certificate from an independent Chartered Accountant who had verified the books of account of the Company and confirmed the fact that the ITC amount as stated above had been passed on by him. Copy of the Certificate obtained from the independent Chartered Accountant was enclosed. This also author evidences the fact that the ITC benefit had been passed on by the Respondent. Also, copies of the Credit Notes and corresponding customer statement of accounts further evidencing this fact were enclosed. m. The methodology and procedure/mechanism of computation of "profiteering amount" adopted by the DGAP is wrong, incorrect, arbitrary, illegal and bad in law. As per Rule 126 of the Rules, this Authority bad been empowered to determine the methodology and procedure for determination as to wh....
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....ability from his own without having received the actual demands raised to customers. Therefore, the actual benefit of ITC accrued to the service provider could only be ascertained at the time of completion of the project. In view of this fact, the time periods taken by the DGAP for comparison of ITC available to the Respondent was incorrect and bad in law. o. Further, he had passed on the benefit of ITC to the customers of the project 'Prestige Lake Ridge' before completion of the project and handing over the possession of the apartment/flat/unit to the customers. Hence, it would be incorrect to say that the Respondent is liable to pay interest on the benefit actually passed on the customers before handing over the possession of the apartment/flat/unit and actual completion of the project However, the Respondent had already passed on more benefit of ITC as computed by the DGAP in his investigation reports. Therefore, in light of these facts, the Respondent had passed on more benefit of ITC which was actually required to be passed on as per the DGAP's investigation and that had also been passed on well within the time and thus no interest is liable to be passed on further t....
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....had duly been mentioned in the report dated 18.11.2021 submitted by the DGAP. This certificate was submitted by the Respondent in compliance with the observations made by the Authority in Para 36 of the I.O. No.01/2021 dated 16.03.2021, requiring him to produce a third party verification certificate validating his claim of having passed on the benefit of ITC. Therefore, the Authority might decide on the issue of submission of "C A Certificate" made and contested by the Respondent. d. The contention of the Respondent is erroneous. As per Rule 126 of the CGST Rules, 2017, the Authority had 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 had been passed on by the registered person to the recipients by way of commensurate reduction in prices. The Authority in exercise of power delegated to it under Rule 126 of the CGST Rules, 2017, had notified the Methodology & Procedure vide Notification dated 28.03.2018 which is also available on the website. No fixed/uniform mathematical methodology could be determined for all the cases of profiteering as the facts and circumstances of....
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....se, the DGAP received reference from the Standing Committee on Anti-Profiteering on 09.10.2019 to investigate the matter, hence the period from 01.07.2017 (date of implementation of GAT law) up to the preceding up to preceding month of receipt of reference was taken up for investigation (post- GST) i.e., from 01.07.2017 to 30.09.2019. This practice is uniformly adopted by DGAP in respect of all investigations to cover the period of investigation up to the preceding month of the month when the reference is received in this office. It was further clarified that the DGAP and the Authority was statutorily required to complete his task within a given time frame. Therefore, the ITC availed and the consequential profiteering, if any, had to be determined at a given point of time and such determination cannot be deferred tilt the completion of the project. Hence, the investigation was done up to 30.09.2019 which could not be deferred till the completion of the project. Furthermore, to address the contention of the Respondent that the construction services was entirely based on milestones and taxable turnover and actual receipt of demands differ in general, it is submitted that even the hom....
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....it of ITC available to him during the GST regime for the impugned Project as calculated by the DGAP in its Investigation Report dated 28.08.2020 and has agreed to pass on the benefit of such ITC to the recipients. Hence, the Authority vide its I.O. No. 01/2021 dated 16.03.2021 accepted the mathematical computation of the benefit of ITC available to the Respondent during the GST regime as calculated by the DGAP in its Investigation Report dated 28.08.2020 for the impugned Project as well as determined that if such amount of ITC benefit is not passed on then it would be the amount profiteered by the Respondent in terms of Section 171 of the CGST Act, 2017. There has been no contest by the Respondent to such I.O. No. 01/2021 dated 15.03.2021 of this Authority. Hence, this Authority finds that, the matter relating to availability of benefit of ITC to the Respondent with respect to the impugned Project and calculation thereof recipient wise stand concluded. 10. However, as mentioned in earlier paragraphs, as per the directions of this Authority's I.O. No. 01/2021 dated 16.03.2021, the DGAP has carried out this investigation in the subject matter to establish whether the benefit of IT....
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....cate (as Third patty verification) and Confirmation (4 on sample basis) from the Homebuyers as supporting documents against his claim. Further, to cross check the claim of the Respondent, 174 home buyers (whose emails ids were provided by the Respondent), who were contacted by the DGAP to verify the claim of the Respondent via mails, 142 had not responded and 31 homebuyers including the Applicant No. 1 confirmed the receipt of the payment made by the Respondent. The Applicant No. 1, vide his email dated 25.07.2022 to this Authority, has also confirmed receiving an amount of Rs. 1,75,850/- from the Respondent, however, it is observed that the amount of profiteering computed in respect of the Applicant No. 1 by the DGAP was Rs. 1,71,662/-. The Respondent had submitted that he bad passed on the benefit of Rs. 8,28,91,520/- to 453 homebuyers. However, the DGAP could only verify the amount of Rs. 36,44,497/- passed on to the 31 home buyers, who had confined the receipt of the benefit of ITC from the Respondent Hence, it is concluded by the DGAP that the Respondent's claim of passing on benefit of Rs. 8,28,91,520/- could not be verified and the Respondent is yet to pass on the benefit of....
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....tent behind the law, the Authority had been empowered to determine/expand the procedure and methodology in detail. However, one formula which fits all unmet 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 ne 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 units. 14.2 The Respondent has contended that, the tim....
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....the homebuyers/customers by way of commensurate reduction in prices in tents of Section 171 of the CGST Act, 2017. However, it is observed that the benefit was not commensurately passed on by the Respondent to his recipients. 16. The Authority finds that, taking into account the aforesaid Input Tax Credit availability post GST and the details of the amount collected from the home buyers during the period 01.07.2017 to 30.09.2019, the amount of benefit of ITC not passed on to the recipients or in other words, the profiteered amount comes to Rs. 7,90,95,475/- (i.e. 7,06,20,959/- + Rs. 84,74,515/- i.e. GST thereon) in respect of 452 homebuyers. 17. The Respondent has claimed that be had already passed on a substantial amount of GST ITC per the requirements of Section 171 of the CGST Act, 2017 to the homebuyers. The Respondent had submitted that he had passed on the benefit of Rs. 8,28,91,520/- to all the homebuyers/customers. The Respondent has also claimed that he has passed on excess ITC benefit to his buyers/customers. The DGAP has responded to such claims as tabulated at Table A above and fund that Respondent has not passed commensurate benefit to all homebuyers/customers. T....
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....ven facts and circumstances and also stated position of law we find that the Respondent has denied the benefit of ITC to the buyers of his flats in contravention of the provisions of Section 171 (1) of the CGST Act 2017. The Authority holds that the Respondent has committed an offence by violating the provisions of Section 171 (1) during the period from 01.07.2017 to 30.09.2019, and therefore, he is liable for imposition of penalty under the provisions of Section 171 (3A) of the above Act. However, perusal of the provisions of the said Section 171 (3A) shows that it has been inserted in the CGST Act, 2017 w.e.f. 01.01.2020 vide Section 112 of the Finance Act, 2019 and it was not in operation during the period from 01.07.2017 to 30.09.2019, when the Respondent had committed the above violation. Hence, the said penalty under Section 171 (3A) cannot be imposed on the Respondent retrospectively. 21. However, the Authority finds that the Respondent may also be executing other projects under the same GST Registration No. 29AABCP8096K1ZP and the issue of profiteering may arise in the other projects as well. In view of the observation made in the earlier paragraph, the Authority fords t....
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....s clear from the said Order which states as follows:- "A period of limitation in all such proceedings, irrespective of the limitation prescribed under the general law or special laws whether condonable or not shall stand extended w.e.f. 15th March 2020 till further order/s to he passed by this Court In present proceedings." Further, the Hon'ble Supreme Court, vide its subsequent 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. 27.01.2021 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. 25. A copy each of this Order be supplied free of cost to the Applicants, the Respondents, Commissioners CGST/SGST Karnataka, the Principal Secretary (Town and Co....
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....07 351 Sukhost Randava Shetty 11003 204155 11094 153053 33 Pashanth Desa 11095 154583 354 Vika 11096 132633 155 Girish kete 11101 157600 356 Vinay Komai N5 11103 130352 357 Asta GA 11204 191754 398 Subramanyam YA 11105 155455 159 Anil Kumar San 11105 113075 150 Preush AV 11111 154945 11323 205398 11315 147753 11116 133467 16 P Rahu 355434 365 Vitta investients 31223 13105: 366 Keerthanath 11124 151672 367 Sathya Shamar KA 11125 153354 568 Sudheendra Rao 11176 166895 19 Mutian A R 155812 1701 ΠΑ X52053 17 11345 227073 Vatsay shek 11146 188585 17 Arun Kulia 11101 156819 374 Jayashree URS 11162 218318 375 Krushal Sunil Shan 11163 150343 376 Anand BG 11165 157813 177 Spadaraja Purushothama 11100 215355 1/8 Mrangan B 111/2 255933 129 Axww Vindey 1117 100435 11375 156712 ш 162 Stasidha 21185 132006 393 T Rawsdvartis Tagore 11185 245832 384 Chandrakanth P Donagar 12003 2:0249 15 Mangatna M 120....