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2022 (10) TMI 461

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....profiteering by the Respondent in respect of purchase of Flat in the "Godrej 24" project of the Respondent. II. A Notice under Rule 129 of the CGST Rules, 2017 was issued by the DGAP on 14.01.2019 calling upon the Respondent to reply as to whether he admitted that the benefit of ITC had not been passed on to the Applicant No. 1 by way of commensurate reduction in price and if so, to sun moto determine the quantum thereof and indicate the same in his reply to the Notice as well as furnish all supporting documents. III. The period of investigation was from 01.07.2017 to 31.12.2018. IV. As per the directions of the Authority issued vide Internal Order No. 08/2020 dated 03.01.2020, the DGAP initiated a re-investigation of the case. The case had been re-investigated on the basis of new data submitted by the Respondent. The main issues/ Paras raised by the Authority vide Internal Order No. 08/2020 and ensuing DGAP findings were as follows:- a) Para 71 "It is further revealed from the record that the Respondent had claimed that the carpet area relevant to turnover considered by the DGAP was incorrect. He had also supplied both the figures which had been....

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....he Respondent had vehemently claimed in his submissions that the total number of the units in his "Godrej 24" project was 816. Since there is a vast difference in the number of units claimed by both the parties the same is required to be reconciled". DGAP's Reply on Para 74 - The contention of the Respondent that the total number of units in his "Godrej 24" Project was 816 in place of 892 units had also been examined. The submission of the Respondent had been verified with the details available on the Maharashtra RERA website wherein tower-wise units had been mentioned and it is observed that there were 815 units. On being pointed out it, had been clarified by the Respondent vide his email dated 24.01.2021 that the number of units in the project was 816, and the number of units registered in RERA was 815 units since one unit is being kept as a guest house to be managed by the society. Accordingly, the element of profiteering had been recalculated as detailed in the following para(s) considering the 816 units claimed by the Respondent. e) Para 75: "The Respondent had also contended that the DGAP had considered the area of cancelled flats while computing the pro....

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....ticulars 'Total (Pre-GST) April, 2016 to June, 2017 Taxable Turnover (July, 2017 to December, 2018) 1. CENVAT Credit of Service Tax Paid on Input Services (A) 1,33,30,931 - 2. Credit of VAT paid on Purchase of Inputs(B) - - 3. Input tax credit of GST Availed (C)   12,87,59,004 4. Total CENVAT/Input Tax 1,33,30,931 Credit Available (D)=(A+B+C) 1,33,30,931 12,87,59,004 5. Turnover for Flats as per Home Buyers List (E) 22,10,80,012 1,69,15,88,954 6. Total Saleable Area (in SQF) (F) 9,48,024 9,48,024 7. Total Sold Area (in SQF) relevant to turnover (G) 4,74,873 8,29,064 8. Relevant ITC [(H)=(D)*(G)/(F)] 66,77,573 11,26,02,060 The Ratio of ITC Post-GST [(I)=(H)/(E)] 3.02% 6.66% From the above Table- 'A', it is clear that the ITC as a percentage to turnover as available to the Respondent in the pre-GST regime was 3.02% and the same during the post-GST period had been calculated as 6.66% for the Project "Godrej 24". Therefore, the Respondent had benefited from additional ITC to the tune of 3.64% [6.66% (-) 3.02%1 of the turnover. On the basis of the figu....

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.... Respondent had provided the benefit of ITC passed on to individual homebuyers based on the data given by Respondent vide email dated 28-01-2021. The Respondent had claimed to have passed on the ITC benefit to 647 Customers as detailed in his home buyer list submitted vide his email dated 17.09.2020. The submission of the Respondent had been cross-checked with the home buyers by way of sending e-mails to the major stakeholders as a matter of practice to ascertain the genuineness of the claim of the Respondent. Out of the 344 e-mails sent to the major stakeholders, only 86 stakeholders responded. Out of these 59 home buyers had confirmed the receipt of ITC benefit as claimed by the Respondent, 15 stakeholders had denied the receipt of ITC benefit and 12 stakeholders had submitted incomplete replies from which no inference could be drawn. Therefore, the amount of ITC benefit passed onto these 59 home buyers had been considered by the DGAP and due to the absence of warranted documentary evidence in the case of the remaining home buyers, the ITC benefit as claimed to have passed on by the Respondent had not considered by DGAP. A detailed break-up of ITC as claimed to have been passed o....

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....observed that the remaining 31 home buyers out of these 59 home buyers received a total ITC benefit of Rs. 37,35,333/-whereas the proportionate eligible amount of ITC which was supposed to be passed on is Rs. 37,71,438/- and this difference amount is accordingly adjusted form the Profiteering amount of Rs.6,89,92,698/- final amount of profiteering. Table 'D' Category of home buyers No of home buyers Actual ITC benefit passed on by the Respondent to mentioned home buyers   Proportionate eligible ITC benefits which had to be passed on to the home buyers Pending eligible ITC benefit to be given (Proportionate ITC to be given - Actual ITC benefit given)     A B C Home buyers with excess ITC 28  (54,29,635) 32,89,455 -21,40,180 Home-buyers with deficit ITC 31 (37,35,333) 37,71,438 36,105 Total 59 91,64,968 70,60,893 36,105 V. The excess amount of ITC benefit Rs. 21,40,170/- given to the 28 home buyers (categorized as home-buyers with excess ITC) and the difference amount of Rs. 36,105/-which had to be given to the 31 home buyers (categorized as home-buyers with deficit ITC) was ....

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....he tax invoice itself C. Sub-Total (A+B) 669 8,06,63,836   D. Customers who booked units after 30.06.2018 till 31.12.2018 68 In respect of units booked after 1 year of introduction of GST, the price offered to customers is after considering the benefit of ITC as per Section 171 of the CGST Act and other market conditions. E. Unsold Units as on 31.12.2018 79   F. Total Units (C+D+E) 816   A.3 The Applicant belongs to Category A i.e. it has booked the unit in earlier regime. It is a fact on record that the Respondent has passed on the benefit of 3.88% of the turnover to the Applicant, which is being duly reflected in the invoices raised to the Applicant in GST period. The Applicant in its applications has also admittedly pointed out that the Respondent has passed on GST benefit of 3.88% of the turnover. The same way UST benefit was passed back to all other customers falling in Category "A". The proof of benefit passed on to all the customers along with the amount of benefits passed on have been submitted to DGAP. A.4 The undertakings of 17 customers evidencing that customers have received the benefit of input tax cr....

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....rt from the DGAP. Further, the Authority has powers to seek clarifications from DGAP u/r 133(2A) and also refer the matter to DGAP to cause further investigation or inquiry in accordance with the provisions of the Act and the rules, if the Authority is of the said opinion that further investigation or inquiry is required. C.2 The fresh time limit available to a new investigation is not available to a further investigation u/r 133 (4), and that the further investigation u/r 133 (4) needs to be completed and final order of the NAA needs to be passed within the overall time limit of 6 months from the date of receipt of original report of DGAP provided in rule 133(1). Respondent further submits that every time an order is passed by the NAA u/r 133 (4) of the CGST Rules, if a fresh time limit is made available to DGAP to furnish report based on further investigation to be carried out by it and for NAA to pass an order, it will lead to a situation where the proceedings will not attain finality at any point of time. C.3 Therefore, the DGAP furnished its original report to NAA on 26.06.2019, the NAA is required to pass a final order within 6 months from 26.06.2019, that is by 25.12.2....

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....e before the Hon'ble Delhi High Court in DRA Aadithya Projects Pvt. Ltd. vs UOI & Ors. (W.P. (C) 2970/2021). D.6 Accordingly, an amount of INR 3,15,57,382/- needs to be excluded from the total profiteering determined in the DGAP report. The calculation of INR 3,15,57,382/- is as follows: A Turnover for Units booked in GST regime i.e. between 01.07.2017 to 31.12.2018 Rs.77,40,72,371/- B Anti-profiteering % computed by Ld. DG 3.64% C Additional GST also alleged to be collected from customers 12% D Amount of profiteering computed by Ld. DG for the units booked in GST regime [A*B*(1+C)] Rs. 3,15,57,382/- E. The land value shall be excluded for calculation of the profiteering amount. E.1 He has collected from its customers not only the value of taxable construction services, rather it also collects the value of land from its customers. Further, sale of land and, subject to clause (b) of paragraph 5 of Schedule II, sale of building are not treated as supply as per Schedule III of the CGST Act. Further, it is submitted that sale of land is covered under stamp duty regulations and appropriate stamp duties are paid on the same. E.2 The Res....

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.... the correct quantum of profiteering. F.2 The comparison of above ratio is not appropriate for the reason that under the real estate sector, there is no correlation between turnover and the cost of construction or development of a project. The turnover reflects the amount billed by developer as per payment or booking plans issued by it which is purely based on market-driven strategy. On the contrary, the input tax credit is accrued to a developer on the basis of actual cost incurred by it while undertaking the development of a project. Thus, accrual of input tax credit is not dependent on the amount collected from the buyers. In this industry, advance is received by the developers even before the commencement of the projects. Likewise, units are sold after the completion of the project as well. Thus, receiving of inputs/input services and taking credit of the same does not have an immediate and direct relation with the turnover in real estate sector. Accordingly, calculating profiteering on the basis of turnover could not reflect the correct outcome for the Respondent. F.3 Respondent submitted that the calculation of alleged profiteering based on the comparison of ratio of in....

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.... base price during the relevant period vis-à-vis the recalibrated base price, excluding the GST amount. The Respondent submitted that the amount charged as GST by the Respondent has been duly deposited in the government account. The GST has been charged over and above the value of construction services supplied by the Respondent, so, the amount of GST collected by the Respondent from its customers on the alleged profiteering amount stands paid to the government exchequer. H.2 Assuming, without admitting, that the Respondent has profiteered and GST has been collected thereon and said GST is to be paid in Consumer Welfare Fund then instead of Respondent, the Government can transfer the amount equivalent to GST on the profiteered amount to the Consumer Welfare Fund. H.3 Respondent submitted that since the amount collected as GST by the Respondent from the recipient on the alleged profiteering amount has already been deposited with Government and there is no factual dispute by the DGAP on this aspect, the addition of 12% GST to calculate the alleged profiteering amount is incorrect, not sustainable and liable to be rejected. H.4 Accordingly, an amount of INR 73,88,861/-....

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....be initiated only on receipt of a written application from an interested party, commissioner or any other person. In the instant case, the proceedings were initiated on the basis of an application received from the Applicant. It is pertinent to mention that the said application was only in respect of one Flat purchased by the Applicant in the 'Godrej 24' project. Hence, the investigation cannot go beyond the application and cover other customers also who have not questioned the benefit passed on to them. J.3 In this regard, reliance is placed on the following orders of the Authority, wherein investigation, report and final order of the Authority was only on the product for which complaint was filed in the respective cases: 1. M/s U P. Sales & Services vs. M/s Vrandavaneshwree Automotive Private Limited. 2. Shri Rishi Gupta vs. M/s Flipkart Internet Pvt Ltd. J.4 Reliance is also placed on the decision of- • Kerala State Screening Committee on Anti-Profiteering, Director General Anti-Profiteering v. M/s Pulimoottill Silks reported at 2019 (2) TMI 296 - THE NATIONAL ANTI-PROFITEERING AUTHORITY. • Kerala State Screening Committee on....

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....es the procedure pertaining to investigation and hearing. However, no method/formula has been notified/prescribed pertaining to calculation of profiteering amount. Further, absence of such a mechanism or framework within which the Authority/DGAP must discharge its duties would also lead to arbitrariness. K.4 On the basis of the aforementioned discussions, it is submitted that in absence of prescribed method/formula for calculation of profiteering, following a method on the case-to-case basis is arbitrary and thus, the report is liable to be rejected. L. Section 171 of the CGST Act cannot be applied to compare credit in the erstwhile regime with the input tax credit under the GST regime. L.1 The Respondent submitted that section 171 of the CGST Act is not applicable in the facts of the present case. Section 171 of the CGST Act provides for passing the benefit of reduction in the rate of tax on any supply of goods or services or benefit of an input tax credit, to the recipient by way of commensurate reduction in price. L.2 The Respondent submitted that the benefit of ITC can only arise within the GST regime, on a change in the provision relating to ITC, and transition fro....

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....sustainable. N.4 The Respondent submitted that he reserves the right to challenge the present proceedings on the following grounds before appropriate forums: a) In absence of a judicial member, the constitution of NAA is improper; b) Section 171 of the CGST Act and Rules made thereunder pertaining to anti- profiteering are unconstitutionally being violative of Article 14 and Article 19 (1)(g) of the Constitution of India; c) Rules 126, 127 and 133 of the CGST Rules suffer from the vice of excessive delegation; d) Non-prescription of any methodology or guidelines renders the investigation report unsustainable; e) The proceedings being violative of principles of natural justice are liable to be dropped in entirety. 4. Supplementary Reports dated 09.05.2022, 21.07.2022, and 02.08.2022 was sought from the DGAP on the above submissions of the Respondent. In this regard, para-wise clarification with regards to the Respondent's objection is as follows:- a. The alleged profiteering figures are less than the benefit already passed on by the Respondent. As per Section 171 of CGST Act 2017, any benefit of tax reduction h....

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.... also stand excluded in computing the limitation period as per the hon'ble Supreme Court's order dated 27.04.2021 passed in miscellaneous application no 665/2021 in SMW(C) No. 3/2020. Further, the above relief has been extended and the period from 02.10.2021 shall have a limitation period of 90 days from 03.10.2021 as per the Hon'ble Supreme Court's order dated 23.09.2021 passed in miscellaneous application no 665/2021 in SMW(C) No. 3/2020. Hence, the proceedings were not time-barred. c. Fresh negotiations/bookings on or after 01.07.2017 shall be excluded from the calculation of the profiteering amount. The averment made by the Respondent is incorrect. Respondent has benefitted from additional ITC only after the introduction of the GST. This additional benefit of ITC pertains to the entire project or in other words, relates to each flat/unit of the project of the Respondent. Hence all unit/flat buyers are eligible to get their due benefit of ITC from the Respondent irrespective of their bookings made in the pre-GST or post-GST period. Whatever the negotiated price, the benefit of additional ITC has to be specifically passed on to all the recipients....

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....methodology to compute the benefit of additional ITC which would be required to be passed on to the buyers of such units. The CGST Rules have provided an elaborate mechanism for determination of the benefits and hence there is sufficient machinery to implement the anti-profiteering provisions. The benefit of additional ITC passed on, if any, is considered after the profiteered amount is worked out. f. The alleged profiteering amount has been incorrectly inflated in the report by adding GST and the same is not sustainable Section 171 (1) of the CGST Act 2017 envisages that any reduction in the rate of tax or the benefit of the input tax credit has to be passed on to the recipient by way of a commensurate reduction in price. In other words, every recipient of goods or services has to get the benefit from the supplier, and hence, this benefit has to be calculated for every product supplied. The GST on the profiteered amount is collected by the Respondent from the recipient of the supply, which ought not to have been collected as the profiteered amount itself was not to be collected. Since the recipient of supply has borne the entire burden of profit....

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....of each supply of Stock Keeping Unit (SKU) to each buyer of such SKU and in case it is not passed on, the profiteered amount has to be calculated on each SKU. The computation of commensurate reduction in prices is purely a mathematical exercise which is based upon the above parameters hence it would vary from product to product and hence no fixed mathematical methodology can be prescribed to determine the amount of benefit that a supplier is required to pass on to a recipient or the profiteered amount. i. Absence of issuance of Show Cause Notice, proceedings initiated are in violation of the principles of natural justice: The Respondent has contended that no show cause notice was issued. In this regard, it is submitted that on receipt of the application/complaint, the DGAP had issued a notice dated 14.01.2019 to the Respondent to reply as to whether they admitted that the benefit of ITC had not been passed on to the recipient by way of commensurate reduction in the price and furnish supporting documents. Likewise, upon receiving the investigation report, the NAA also issued a notice dated 09.03.2021 to the Respondent to show cause why the said report should not be....

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.... Section 171 of the CGST Act, 2017. b. Whether the Respondent is liable for imposition of penalty under the provisions of Section 171 (3A) of the CGST Act, 2017. c. The issues raised by the Respondent in his various submissions, are as under : - i. Whether the profiteering figures are less than the benefit already passed by the Respondent? ii. Whether the fresh negotiations/bookings done by Respondent, on or after 01.07.2017 could be excluded from the calculation of the profiteering amount? iii. Whether the anti-profiteering proceedings are time-barred? iv. Whether the land value should be excluded from the calculation of the profiteering amount? v. Whether the Comparison of the ratio of input tax credit to turnover for the pre-GST period and GST period is not the correct mechanism for the calculation of profiteering amount? vi. Whether the profiteering amount has been incorrectly inflated in the DGAP report by adding GST? vii. Whether DGAP report cannot go beyond the application submitted by the Applicant No. 1'? viii. Whether in the absence of prescribed method of calculation of profitee....

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.... denied the receipt of ITC benefit and 12 recipients/customers had submitted incomplete replies from which no inference could be drawn. As per the said Report, only 59 home buyers/customers/recipients out of all 719 eligible home buyers/customers/recipients have confirmed receipt of some ITC benefit and the passing on of benefit of ITC to the remaining home buyers/customers/recipients has either not been verified or they did not respond to the communication made by the DGAP. Thus, verification 719 was reported to be done in respect of only 59 out of all eligible customers/recipients has been submitted. Also, of such 59 recipients, 31 are said to have received only partial benefit. Hence, this Authority finds that, the above claims of the Respondents and the DGAP's verification is neither definitive nor conclusive. Hence the Authority finds that neither the claim of he Respondent nor the verification done thereof to determine authenticity of such claim is acceptable. II. The Respondent has contended that the fresh negotiations/bookings on or after 01.07.2017 shall be excluded from the calculation of the profiteering amount. The Authority finds that, there is no....

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....n it was held that:- "37. Procedural laws, like the Code, are intended to control and regulate the procedure of judicial proceedings to achieve the objects of justice and expeditious disposal of cases. The provisions of procedural law which do not provide for penal consequences in default of their compliance should normally be construed as directory in nature and should receive liberal construction. The Court should always keep in mind the object of the statute and adopt an interpretation which would further such cause in light of attendant circumstances. To put it simply, the procedural law must act as a linchpin to keep the wheel of expeditious and effective determination of dispute moving in its place. The procedural checks must achieve its end object of just, fair and expeditious justice to parties without seriously prejudicing the rights of any of them." In view of the above, it is legal and proper to hold that the time limit specified under Rule 133 of CGST Rules is directory in nature. IV. The Respondent has contended that land value should be excluded from the calculation of the profiteering amount. The Respondent has also contented that ....

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....y the Respondent and have been duly verified from their Service Tax and GST Returns filed by them for the period April 2016 to June 2017 and July 2017 to December 2018 respectively. Since the ratios calculated by the DGAP are based on the factual record submitted by them; hence they can be relied upon while computing the profiteered amount. The above methodology had been approved by this Authority in all the cases where the benefit of ITC was required to be passed on to the flat buyers/recipients of construction service. VI. The Respondent has contended that the Alleged profiteering amount has been incorrectly inflated in the report by adding GST and the same is not sustainable. The Authority concurs with the view taken by the DGAP here. The GST on the profiteered amount is collected by the Respondent from the recipient of the supply, which ought not to have been collected as the profiteered amount itself was not to be collected. Since the recipient of supply has borne the entire burden of profiteered amount as well as GST on that amount, the Respondent is obliged to pass on the entire amount to the flat buyers in terms of Section 171 of the CGST Act, 2017, irresp....

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.... It is clear from the plain reading of the above provision that it mentions "reduction in the rate of tax or benefit of ITC" which means that if any reduction in the rate of tax is ordered by the Central or the State Governments or a registered supplier avails benefit of additional ITC as a result of coming in to force of the GST, the same have to be passed on by him to his recipients as both the above benefits are being given by the above Governments out of their tax revenue. The computation of the profiteered amount is a mathematical exercise that can be done by any person who has knowledge of accountancy and mathematics keeping into consideration the facts and situation of the case. To implement the legislative intent behind the above provision, this Authority has been authorized to determine the 'Procedure and Methodology'. This has been done by it vide its Notification dated 28.03.2018 under Rule 126 of the CGST Rules, 2017 in consonance with the provisions made under Section 171 (1) of the CGST Act 2017, which is very clear in its intent, therefore, the contention of the Respondent is without any basis. The anti-profiteering provisions get actuated whenever there is reduc....

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....le proceedings initiated and investigated by DGAP have been conducted in accordance with the provisions of the law. The DGAP report has come to a prima facie conclusion regarding the amount of the profiteered amount based on the documents and data provided by the Respondent. No rights of the Respondent, whatsoever, have been contravened by the DGAP during the course of investigation. The Authority has given ample opportunity to the Respondent to reply or make submissions in respect of the report and all those submissions have been duly taken into consideration by the Authority. The Respondent has also been offered a personal hearing in the matter and based on the submissions made during all the proceedings, the instant order is being passed. The above-said facts and circumstances clearly demonstrate that no violation of principles of natural justice has taken place against Respondent. They have been provided with a notice with proposed course of action, on the basis of investigation conducted and prima facie conclusion drawn on the basis of the documents and data submitted by them. Their submissions have been duly taken into consideration while passing the instant order. Hence, the....

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....rest as applicable on the entire amount profiteered, i.e. Rs. 6,89,62,698/- for the project "Godrej 24". Hence the Respondent is directed to also pass on interest @18% to the customers/ flat buyers/ recipients on the entire amount profiteered, starting from the date from which the above amount was profiteered till the date of passing on/ payment, as per the provisions of Rule 133 (3) (b) of the CGST Rules, 2017. 12. This Authority also orders that the profiteered amount of Rs. 6,89,62,698/- for the project "Godrej 24" along with the interest @ 18% from the date of receiving of the profiteered amount from the customers/flat buyers/recipients in the Project "Godrej 24", till the date of passing the benefit of ITC shall be paid/passed on by the Respondent to each customer/flat buyer/recipient within a period of 3 months from the date of this Order failing which it shall be recovered as per the provisions of the CGST Act, 2017. 13. The details of the eligible customers/flat buyers/recipients in the Project "Godrej 24" and benefit which is required to be passed on to each customers/flat buyers/recipients along-with the details of the unit are contained in the Annexure 'A' ....

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....ner shall also submit a Report regarding the compliance of this order to the Authority and the DGAP within a period of 4 months from the date of receipt of this order. 17. Since the Respondent has profiteered in the instant project, there is every likelihood that he has profiteered in other projects also under the GSTIN:27AAICP7601B1ZO. The Authority has reasons to believe that the Respondent may have resorted to profiteering in the other projects also and hence, it directs the DGAP under Rule 133 (5) to investigate all the other projects of the Respondent under the same GST registration which have not yet been investigated from the perspective of Section 171 of the CGST Act, 2017 and submit complete investigation report for all the Projects under this single GST Registration. 18. The present investigation has been conducted up to 31.12.2018 only. However, the Respondent is liable to pass on the benefit of ITC which would become available to him till the date of issue of Completion Certificate. Accordingly, the concerned jurisdictional Commissioner CGST/SGST are directed to ensure that the Respondent pass on the benefit of ITC to the eligible home buyers/customers/recipients ....

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....0031906 MILIND GTFTF20901 116,406 32 10033590 MUSTAFA KHOZEMA GTFTG11302 29,101 33 10031946 NARINDER GTFTE21301 38,024 34 10031905 NILESH P GTFTG10502 116,406 35 10031033 NIRAV GTFTD21502 145,104 36 10031957 NITIN R GTFTG11502 28,768 37 10032524 P ANBU GTFTG10801 28,631 38 10031945 POULAMI GTFTD51101 116,406 39 10031915 PRADEEP GTFTF21201 113,214 40 10031849 PRAMATH GTFTE41202 149,700 41 10031069 PRANAM GTFTF21502 116,083 42 10034062 Pratik GTFTD21602 28,631 43 10033670 PRIYANK GTFTD20802 28,631 44 10026795 PUKHRAJ GTFTF21001 110,112 45 10031949 RAJASHRI SUBHASH GTFTF11102 115,396 46 10032753 RAJAT D GTFTD11302 29,101 47 10029485 RAVI GTFTE10801 38,729 48 10032167 RAVIKANT GTFTD10702 29,101 49 10032317 Rohit GTFTF20902 29,101 50 10032926 RUPALI GTFTF11401 28,631 51 10031718 SACHIN GTFTD41301 145,104 52 10029559 SAI PRASANTH GTFTF20901 7,095 1 of 14 Order no. 77/2022. Parvez Khan Vs Pearlite Real Prop. P. Ltd Customer....

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....GTFTD30704 71,340 95 10023910 JYOTIRMOY NANDI GTFTE10702 179,782 96 10023911 KUSHAL CHANDUMAN LOKHANDE GTFTD40702 106,475 97 10023913 RAHUL TELANG GTFTD10304 90,607 98 10023914 LUKESH SHRIRAM GTFTD30504 61,288 99 10023915 ABHISHEK CHADHA GTFTE10704 105,379 100 10023916 ARPIT ACHARYA GTFTD20404 79,754 101 10023917 RIYA RAJAN GTFTD40804 81,213 102 10023918 VIJAY BHASKAR REDDY DATLA GTFTD40501 108,416 103 10023919 SWETA GTFTE20401 131,955 104 10023920 MANOJ NARAYANDAS PAGARIYA GTFTD41003 79,754 105 10023921 MAHADEVI M KALSHETTI GTFTD40701 106,475 2 of 14 Order no. 77/2022. Parvez Khan Vs Pearlite Real Prop. P. Ltd Customer Sl.no. Customer Name Flat Code Code Profiteering Amount (Rs.) 106 10023922 K Ram Shankar GTFTD31303 81,521 107 10023924 Shankar A Reddy GTFTD31103 62,958 108 10023925 ABHISHEK GTFTD21703 96,452 109 10023926 Kirtikumar Gopaldas Agrawal GTFTD30703 61,288 110 10023932 Anupam Gangwar GTFTD10401 103,422 111 10023936 SUSHIL BADGUJAR GTFTD1150....

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.... 10024036 Yogesh Suresh Sethia GTFTE30301 97,801 154 10024038 SHASHANK KULKARNI GTFTD10302 107,446 155 10024040 RISHIKA M GTFTD20104 89,054 156 10024041 Sandesh Suresh Sethia GTFTE30302 97,741 157 10024044 SANCHIT S GTFTE20901 134,869 158 10024047 MANGESH BABASAHEB DHUMAL GTFTE20301 130,075 3 of 14 Order no. 77/2022. Parvez Khan Vs Pearlite Real Prop. P. Ltd Customer Sl.no. Customer Name Flat Code Code Profiteering Amount (Rs.) 159 10024048 SONAM SONI GTFTE41503 73,084 160 10024049 MANJUNATH MALLER GTFTE30501 99,599 161 10024050 BISWARUPA CHATTERJEE GTFTD41004 79,754 162 10024051 VARSHA SANTOSH GTFTE40703 70,519 163 10024052 NEELAM ASWAL NEGI GTFTE31103 82,857 164 10024053 KAILAS KHEMCHANDRA SINGNURKAR GTFTE20403 89,330 165 10024054 SHILPI SHRIVASTAVA GTFTF10404 76,004 166 10024055 RASHMI RASTOGI GTFTE10502 148,816 167 10024056 SAVITA HEMNANI GTFTD11403 83,402 168 10024057 Smita Deshmukh GTFTD10204 79,024 169 10024059 RAMCHANDRA J CHAVAN GTFTD40601 107,240 1....

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.... 210 10024114 DEEPAK MOHITE GTFTE11304 107,305 211 10024116 Shubham Goyal GTFTE41404 70,396 4 of 14. Order no. 77/2022. Parvez Khan Vs Pearlite Real Prop. P. Ltd Customer Sl.no. Customer Name Flat Code Code Profiteering Amount (Rs.) 212 10024117 SANJAY MAHADEV NIKAM GTFTE31304 72,505 213 10024119 Sudesh Pawar GTFTD41403 83,402 214 10024120 BANSRI JAGAD GTFTE40803 68,479 215 10024121 PANKAJ KUMAR GTFTE20604 90,234 216 10024122 RATAN CHOPRA GTFTD11603 84,132 217 10024123 Ajai Viswanathan GTFTF20703 62,958 218 10024124 MANISHA SINGH GTFTD40502 107,446 219 10024125 PRIYA UMESH PUNJABI GTFTF20504 62,401 220 10024134 MEGHNA BHAGWAT GTFTE21501 138,464 221 10024139 AKSHAY KUMAR RAJAGOPAL GTFTE41103 71,801 222 10024141 KARL HOSHI KOLAH GTFTD11504 84,360 223 10024145 ASISH PURI GTFTE31604 71,015 224 10024147 HARISH CHAND SINSINBAR GTFTD10704 81,391 225 10024152 VARAD PRAMOD KELKAR GTFTD20703 81,391 226 10024159 VISHAD H TURAKHIA GTFTD11101 111,327 227 10024....

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....r Sl.no. Customer Name Flat Code Code Profiteering Amount (Rs.) 265 10024232 AMOL GTFTD50203 59,513 266 10024235 VARSHA SHRIVASTAVA GTFTE30803 68,479 267 10024236 MANISH GTFTE30704 70,579 268 10024239 VINAYAK SHRIPAD DATTATRAY KAT GTFTD11602 112,013 269 10024241 NEHA LOHIT GTFTD10301 107,446 270 10024245 SANDEEP ASHOK GHOLAP GTFTD10402 106,285 271 10024246 SOPANRAO GTFTE41403 69,716 272 10024249 NEHA GTFTD41603 84,132 273 10024252 HARDIK BALI GTFTD41604 84,132 274 10024254 HARSH GTFTF21103 64,071 275 10024255 SUDHIR GOVINDRAO DESAI GTFTD30301 80,829 276 10024256 PRANJAL SRIVASTAVA GTFTF21003 73,099 277 10024257 SANDEEP BALWANTRAO PAWAR GTFTE41603 69,097 278 10024258 AASHIMA GUPTA GTFTD40304 80,649 279 10024269 MANISH KUMAR GUPTA GTFTD11303 93,947 280 10024270 DHEERAJ GTFTD21102 111,327 281 10024271 ANKITA JAIN GTFTE21304 116,438 282 10024274 SATISH KUMAR SAHGAL GTFTE10603 101,301 283 10024276 ANSHU ANAND GTFTE10501 178,032 284 1002427....

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.... 322 10024346 Hetal Faeem Shaikh GTFTF20604 61,702 323 10024349 VIVEK KUMAR JAIN GTFTF21104 64,071 324 10024350 Hitesh Tiwari GTFTD30103 67,035 325 10024352 TILAK MRIG GTFTE40202 98,312 326 10024353 RADHIKA NAGARAJ GTFTD51103 62,958 327 10024354 Sweety Paryani GTFTD20402 128,862 328 10024357 ABHISHEK ANAND GTFTE11603 105,939 329 10024361 ABHIMANYU NARAYAMOORTHY GTFTD20603 80,483 330 10024362 SIMSON PASCOAL DSILVA GTFTD21104 83,618 331 10024363 KARISMA SAHA GTFTD21103 83,618 332 10024364 Dheeraj Lohkare GTFTD31604 62,796 333 10024365 DEEPAK SAHA GTFTD21003 81,943 334 10024366 SNIGDHA JYOTIRMAYA SAHOO GTFTD31703 64,628 335 10024368 RISHI SHINAI GTFTD40303 80,649 336 10024369 Ammar GTFTD41303 101,455 337 10024370 Sanjeev Agarwal GTFTE30204 66,683 338 10024373 Vijay Shirur GTFTE40702 100,435 339 10024374 Amit Naidu GTFTD50304 60,731 340 10024376 KAJAL VERDIA GTFTD51204 62,249 341 10024378 ATUL KUMAR SHUKLA GTFTD51503 64,071 342 10024379 Daipayan....

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.... GTFTE31203 69,716 378 10024454 NIWEDITA THAKUR GTFTE20304 92,067 379 10024465 ABHISHEK KUMAR GTFTE20603 90,154 380 10024466 KINNARI TAKAVALE GTFTE10503 102,403 381 10024467 SWAPNIL TALE GTFTE11103 127,070 382 10024468 BHEMRAJ KEDAR GTFTE10703 105,289 383 10024471 Preetham GTFTE21504 97,202 384 10024473 RAKESH NANDLAL DANGAICH GTFTE11604 106,033 385 10024475 Amarjit Singh Nandrajog GTFTE20103 101,199 386 10024476 BYRAM JALIL AHMED KHAN GTFTE20703 93,699 387 10024478 MANGESH YODHA ADMANE GTFTE20903 94,554 388 10024575 ABHISHEK CHATTERJEE GTFTD31404 62,796 389 10024602 Satyanarayana Dora GTFTE20102 141,350 390 10024618 YUGESH GTFTD10403 79,754 391 10024620 DILIPKUMAR GTFTE20802 134,353 392 10024641 ANUJ GTFTG11204 63,344 393 10024642 NITIN GTFTG11004 62,796 394 10024643 SHALABH GTFTG10803 62,249 395 10024645 NARENDRA SINGH GTFTG10203 60,607 396 10024646 APURWA GTFTG10604 61,702 397 10024647 MANGEJ GTFTE31101 104,093 398 10024648 KRISHNA....

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....ENDRA R GAJBHIYE GTFTD30201 80,675 440 10024778 SUBHASH SURENDRA KADDU GTFTE21401 155,072 441 10024834 KIRAN BADGUJAR GTFTD20504 80,649 442 10024839 UJAVAL GTFTG11403 81,111 443 10024840 Sanjay GTFTF20103 86,964 444 10024841 JIGISHA GTFTF11304 82,094 445 10024842 APURVA DHUS GTFTD50701 107,577 446 10024845 RAKESH VASANT PATIL GTFTD41001 134,828 447 10024849 NIHAL AHMED GTFTF21503 75,885 448 10024855 SUYASH GTFTG10404 77,463 449 10024856 RADHIKA GTFTE31704 96,020 450 10024893 PALLAVI VASANTRAO KSHIRSAGAR GTFTF11204 80,382 451 10024894 PRAVIN YASHWANTRAO PATIL GTFTF11203 80,382 452 10024895 Mahesh GTFTE41604 91,436 453 10024896 KRISHAN KUMAR MRIG GTFTG11603 81,841 454 10024897 SHWETA GTFTF21604 75,014 455 10024898 SUSHILA GTFTG11104 81,352 456 10024899 KRISHAN GTFTG11304 82,094 457 10024910 SAKSHAM GTFTD10202 120,522 458 10024912 AARTI GTFTG11203 80,382 459 10024928 KUNAL GTFTF21004 72,461 460 10024931 SHASHI KUMAR GTFTG10204 76,7....

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.... 501 10029473 AKASH GTFTD40704 107,012 502 10027937 AKHILESH GTFTE40104 105,466 503 10029567 ALKA GTFTE20602 181,234 504 10028230 ALKA GTFTD21002 144,568 505 10026841 ALOK MANI GTFTF20403 81,219 506 10027922 AMAR GTFTE31701 145,097 507 10025793 AMIT GTFTD50302 107,928 508 10029151 AMIT GTFTD10901 144,400 509 10028060 AMIT GTFTE40401 137,851 510 10029797 AMIT GTFTD21301 153,432 511 10026483 AMIT GTFTF10704 90,948 512 10028516 AMIT ASHOK GTFTE40801 146,387 513 10029659 AMOL GTFTD31202 115,071 514 10029161 ANIL GTFTG10901 115,520 515 10025804 ANKIT GTFTD20801 137,409 516 10028229 ANURAG GTFTE40701 36,172 517 10026809 APURVA GTFTD10603 101,638 518 10025977 APURVE GTFTD10303 102,792 519 10028240 ARCHANA GTFTD30501 115,188 520 10026436 ARPAN GTFTD50603 81,949 521 10025407 ARTI GTFTE31703 99,742 522 10028091 ARVIND GTFTE40501 138,374 523 10027272 ASHAY GTFTE40901 140,242 524 10025807 ASHISH GTFTD30402 108,68....

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....0025299 KARISHMA S GTFTD50904 84,779 569 10028403 KHALIL GTFTD20401 140,928 570 10029517 KRISHNA KUMAR GTFTF10402 29,011 571 10026624 KULRAJ GTFTD11204 104,938 572 10027252 KUNAL GTFTE30602 138,508 573 10026724 KUNAL GTFTE31302 140,197 574 10029398 LALAN GTFTE20704 122,249 575 10025975 LATA GTFTD50702 111,352 576 10025727 LOKENDRA SINGH GTFTF20303 82,847 577 10026484 MADHAV GTFTD41503 113,584 578 10028241 MADHURI GTFTE10102 211,832 579 10028525 MAHENDRA GTFTD20903 107,932 580 10028379 MAHESH GTFTG10601 113,912 581 10028419 MAMTA GTFTE21602 187,308 582 10026973 MANAS GTFTD50504 83,995 11 of 14 Order no. 77/2022. Parvez Khan Vs Pearlite Real Prop. P. Ltd. Customer Sl.no. Customer Name Flat Code Code Profiteering Amount (Rs.) 583 10027726 MANGESH GTFTD30802 111,556 584 10029657 MANJARI GTFTG10501 113,547 585 10029518 MANJU GTFTD51401 116,042 586 10025803 MANJULA GTFTE30401 134,407 587 10029153 MANOJ GTFTD11102 145,634 588 ....

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.... RAKESH GTFTD51404 GTFTD11202 85,245 143,839 12 of14 Order no. 77/2022. Parvez Khan Vs Pearlite Real Prop. P. Ltd Customer Sl.no. Customer Name Flat Code Code Profiteering Amount (Rs.) 636 10029658 RAM GTFTF20602 112,159 637 10025300 RAM KRISHAN GTFTE20502 169,429 638 10025796 RAMINDER GTFTD21404 105,851 639 10029547 RAVINDRA GTFTD51001 113,130 640 10027334 RAVINDRAKUMAR GTFTE10302 180,030 641 10028606 REHANA GTFTF10602 28,229 642 10028384 REKHA GTFTE11701 37,391 643 10029134 RIYAZ GTFTD31603 89,619 644 10025651 ROHAN GTFTD50401 108,219 645 10026970 ROHAN GTFTD50804 83,421 646 10025374 Rohit GTFTG11002 112,076 647 10025365 Rohit GTFTE31404 95,659 648 10029516 RONALD GTFTF20702 114,533 649 10025482 RUPAK GTFTE30701 136,669 650 10025375 RUTA GTFTF21704 88,127 651 10025791 SACHIN GTFTE41302 138,941 652 10029482 SACHIN GTFTD50602 117,013 653 10027926 SAKETAN GTFTE41704 101,919 654 10028198 SAMAR GTFTE40102 147,716 655....