"Epic" Project: Section 171(1) of CGST Act 2017 Inapplicable Due to Lack of Pre-GST ITC Comparisons.

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....Profiteering - construction of project - benefit of ITC not passed on to the buyers - all the relevant events for the project “Epic” took place in GST regime and the Respondent had not availed any CENVAT/ITC, related to ‘EPIC’ project, in pre-GST regime - there was no pre-GST tax rate or ITC structure which could be compared with the post-GST tax rate and ITC structure and therefore, the provisions of Section 171 (1) of the CGST Act, 2017 were not applicable against the Respondent’s project “Epic” - NAPA....