TaxTMI 
TaxTMI 
2022 (8) TMI 1512
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....ay of commensurate reduction in the price on purchase of Apartment No. 503, Tower-E, from the Respondent in the Project "Panchshil Towers" situated at Kharadi, Pune on the introduction of GST w.e.f. 01.07.2017, in terms of Section 171 of the CGST Act, 2017. 2. The DGAP in his Report dated 25.10.2021, inter-alia stated that: - i. The said application was then examined by the Standing Committee on Anti-profiteering in its meeting, the minutes of which were received in the DGAP's Office on 11.11.2020, whereby it was decided to forward the same to the DGAP to conduct detailed investigation in the matter. Accordingly, an investigation was initiated to collect the evidence necessary to determine whether the benefit of ITC had been passed on by the Respondent to his customers in respect of the construction service supplied by the Respondent. ii. On receipt of the reference from the Standing Committee on Anti-profiteering, a notice under Rule 129 of the Rules was issued by the DGAP on 07.12.2020, Calling upon the Respondent to reply as to whether he admitted that the benefit of ITC had not been passed on to his customers by way of commensurate reduction in price an....
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....e notice dated 07.12.2020, the Respondent submitted documents/ information vide letters and e-mails dated 21.12.2020, 08.01.2021, 08.02.2021, 04.03.2021, 13.08.2021 and 26.08.2021. The Respondent stated that he had passed on the benefit of ITC of Rs.4,25,35,150/- to 53 homebuyers. vii. Vide the aforementioned letters & emails, the Respondent submitted the following documents/ information: a. Copies of GSTR-1 returns for the period July 2017 to November 2020. b. Copies of GSTR-3B returns for the period July 2017 to November 2020. c. Copies of GSTR-9 returns for the period FY 2017-18 & 2018-19. d. Electronic Credit Ledger for the period July 2017 to November 2020. e. Copies of Service Tax for the period of April 2016 to June 2017 & VAT returns for the period April 2016 to June 2017. f. Details of applicable tax rate before and after GST Regime. g. Financial Statement for the FY 2016-17 to FY 2018-19. h. Agreement executed with the landowners. i. Demand letters and Agreement executed with the Applicant. j. Completion Certificate for Tower-A, B, D. and E. k. Details of Tran-1 cre....
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....ax Act and partly for effecting exempt supplies under the said Acts, the amount of credit shall be restricted to so much of the input tax as is attributable to the said taxable supplies including zero-rated supplies". Section 17 (3) "The value of exempt supply under sub-section (2) shall be such as might be prescribed and shall include Supplies on which the recipient is liable to pay tax on reverse charge basis, transactions in securities, sale of land and, subject to clause (b) of paragraph 5 of Schedule II, sale or budding". Therefore, ITC on the unsold units was outside the scope of this investigation and the Respondent was required to recalibrate the selling price of such units to be sold to the prospective buyers by considering the proportionate additional ITC available to him post-GST. xi. The Respondent is a Developer and is engaged in the construction of the buildings. He was earlier registered as an assessee with VAT & Service Tax Department up to 30.06.2017. Thereafter, he was registered with the GST Department vide Registration No. 27AADCP6098D1Z8 foe providing taxable service under the category of construction services. xi....
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....lication form which was signed by all home buyers mentions the terms and conditions at point no. 2 as follows: "Goods and Services Tax plus others tax/levies etc. will be charged additionally as when applicable. The customer acknowledges that the above-mentioned rates are in compliance with the ITC provision as under Section 171 of Central Goods and Services Act, 2017." However, to examine this aspect, all Original application forms concerning all the buyers who had booked flats in the post-GST period were required to be scrutinized. As per the homebuyers list submitted by the Respondent, it was observed that 212 buyers had paid an amount of Rs.3,12,25,31,669/- had purchased the flats from the Respondent in the post-GST period. As such all the Application forms which were signed by the buyers were required to be scrutinized. On scrutiny of these original application forms in respect of 212 buyers, it was found that these documents mentioned that it was agreed between the Respondent and the buyers that the benefit of input credit of GST was already considered in the consideration value and passed on to the said purchaser and henceforth, the buyers....
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....2 11 Recalibrated Base Price J=G*(1-D) or 98.10% of G 90,67,55,767 12 GST @12% K=J*B 10,88,10,692 13 Commensurate demand price L=J+K 1,01,55,66,459 14 Excess Collection of Demand or Profiteering Amount M=I-L 1,96,69,483 xvi. From Table - 'B' above, it was clear that the additional ITC of 1.90% of the turnover should have resulted in commensurate reduction in the base price as well as cum-tax price. Therefore, in terms of Section 171 of the CGST Act, 2017, the benefit of such additional ITC was required to be passed on to the recipients. xvii. It was evident from the above calculation explained in Table B based on the aforesaid CENVAT/ITC availability pre and post-GST and the details of the amount collected by the Respondent from the customers/homebuyers in respect of the flats sold by the Respondent during the period 01.07.2017 to 30.11.2020, the benefit of ITC that need to be passed on by the Respondent to the buyers of flats worked out to Rs.1,96,69,483/- including 12% GST on the base amount of Rs.1,75,62,038/-. The homebuyer and unit-wise break-up of this amount was given in Annex-14 of the Report. This amou....
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....e given by the Respondent for benefit of ITC) 1 1,483 1,15,73,647 2,46,287 8,02,500** 2,46,287 Further Benefit to be passed on as per Annex-17 of the Report 6 Post GST Buyers 212 3,58,503 3,12,25,31,669 0 0 0 Annex-18 of the Report 7 Post OC Sales 80 1,77,687 0 0 0 0 Annex-19 of the Report 8 Unsold Units 369 18,05,542 0 0 0 0 Total 1,040 30,41,375 4,04,68,49,474 1,96,69,483 4,25,35,150 78,13,787 xix. From the above Table "C", it was observed that the benefit to be passed on by the Respondent to 311 homebuyers (Sr. 1,2,3,4 & 5 of above Table- 'C') worked out to Rs.78,13,787/-. The details of the amounts to be passed on to each of the homebuyers were given in Annex-14 & 16 of the Report. The Respondent claimed that he had passed on more than commensurate benefit to certain homebuyers. DGAP has further observed that any excess benefit claimed to have been passed on by the Respondent to some of the recipients cannot be offset against the additional benefit required to be passed on to other home buyers who did not receive the co....
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....ns vide which he stated:- i. That the property/flat was booked after receipt of an offer letter (copy attached with his submissions) dated 25.06.2015. He was verbally assured that the flat would be completed and handed over within 3 years. This was not done and hence putting him under a terrible loan burden. ii. That booking information was received from the Respondent (copy attached with his submissions). This clarified that the cost included Rs. 27 lakhs for Club/ Swimming pool/ Gym and other infrastructure but these facilities were not complete while taking over possession of the flat on 20.02.2020. A mail was sent to the Respondent on the same day apart from conveying the matter on the telephone. iii That ledger information of the amount billed and payment by him was taken from the Website or the Respondent (copy attached with his submissions). It might be seen that the Respondent has taken excess payment over and above the billed amount to the tune of Rs. 17,966,25/-. It was relevant to submit that against his liability to pay Rs.3,31,36,500/- as per the offer letter, he has paid Rs.3,32,47,493.75/-, an excess of Rs. 1,10,493.75/- despite the Governm....
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....ework the same has been held to be incorrect in law. iii. Section 171 is unconstitutional in so far as it seeks to regulate prices That if this finding of DGAP is accepted then Section 171 of the CGST Act is itself unconstitutional as it seeks to regulate prices. It was submitted that under the guise of a tax enactment, the legislature cannot act as a price regulator. It was settled law that prices were governed by market forces and price regulation would be violative of the fundamental right or trade and commerce. Reliance was placed on Indraprastha Gas Ltd. vs. Petroleum and Natural Gas Regulatory Board and Ors. 2015 (9) SCC (209) which has affirmed the above position. iv. The concept of GST being an indirect tax is an economic concept. A supplier cannot be mandated/dictated through a taxing statute to reduce the price to the same extent as benefit accrues due to the availability of ITC. a. That the entire concept of passing on the benefit/ burden of tax to the customer was not envisaged through tax law. The levy of tax under GST was on the supplier and he/she might choose to pass it on to the customer or bear the burden himself/herself. ....
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....placed on the decision in the cases of Commissioner of Income Tax, Gujarat vs. Vadilal Lallubhai AIR 1973 SC 1016 and Indian Aluminium Company vs. Kerala State Electricity Board (1975) 2 SCC 414. c. The term "Profiteering" had been defined as under: S.No. Particulars Reference 1 The taking advantage of unusual or exceptional circumstances to make excessive profits Black's Law Dictionary 2 Make or seek to make an excessive profit Shorter Oxford English Dictionary 3 To seek or obtain excessive profits, one who is given to making an excessive profit Law Lexicon 4 As nouns the difference between profit and profiteering is that profit is total income or cash flow minus expenditures the or other benefit a business receives in exchange products and services sold at an advertised price while profiteering is the act of making an unreasonable profit not justified by the corresponding assumption of risk, or by doing so unethically Wiki Diff online 5 Any conduct or practice involving the acquisition of excessive profits Mount vs Welsh The above meanings/ definitions/ connotations read together with the FAO (supra....
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....y 1, 2017. The said benefit was computed and passed on to all the customers. The Respondent neither intended to nor retained any additional benefit on account of the implementation of GST. Therefore, the Respondent submits that it had fulfilled the requirement under Section 171 of the CGST Act. 2017. c. That the Respondent while opting for the abatement scheme under Service Tax and Composition Scheme under MVAT in the erstwhile regime was not eligible to avail credit of the VAT and Excise Duty paid on the goods used in the construction or the building. Consequently, the Respondent used to an increasing tax burden due to cascading effect of ITC which transpired into costs ultimately borne by the customers Under the GST regime, the said taxes and duties did not remain as in the transaction, and hence, in terms of section 171 of the CGST, the Respondent is required to pass on to the customer. vii That the DGAP had computed the amount of benefit by merely arriving at the difference of ratio of CENVAT Credit to taxable turnover in the pre-GST regime vis-a-vis ratio of ITC to the Taxable Turnover during the period July 2017 to November 2020, which was clearly not ....
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....nvestigation was liable to be set aside was wrong. The GST Council, constituted under Article 279A of the Indian Constitution as a federal, constitutional body, comprising all the Finance Ministers of all the States and UTs and the Union Finance Minister, in its wisdom has rightly not prescribed any Specific guidelines/mechanism/ methodology to determine profiteering in Section 171 of the Act and the Rules made thereunder as the facts of each case are different for different sectors as well as in the same sector also. Hence, no fixed mechanism could have been provided for in the Act or Rules. However, it was submitted that the Methodology and Procedure hud been notified by the Authority vide its Notification dated 28.03.2018 under Rule 126 of the CGST Rules, 2017. Further, any fixed methodology prescribed for all cases could have led to chaos. For example, a real estate project involves various parameters like porcentage completion or the Project, the different proportion of ITC availed because of different purchase patterns of inputs like cement, steel, fittings, etc.; area sold; taxable turnover, etc. before or after the GST implementation, For example, co....
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....endation of the GST Council, which is a constitutional Federal Body under the 101st Amendment of the constitution had formulated and notified Rule 126, 127, and 133 which prescribe the functions, and power of the Authority, All Rules or anti-profiteering have been under Section 164 of the Said Act which has the sanction of the Parliament and the State Legislatures. It also shows that the delegated power to the Authority given under section 171(3) of the Act had been duly exercised by the Central Government by formulating the Rules, on the recommendation of the GST Council. Therefore. the powers to determine the methodology under Rule 126 are just and enable the Authority to clarify and effectuate the powers given and functions to be discharged by the Authority and this enabling provision had been granted to the Authority after careful consideration at several stages and levels and therefore there was no ground claiming that the present delegation was excessive or arbitrary. iii. That the DGAP had not acted in any manner as a price controller or regulator in a free market economy as it does not have the legislative intent to regulate when it comes to price....
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....s not only violated the provisions of the CGST Act, 2017 but had also acted in contravention of the provisions of Section 171 (1) of the Act supra, as he had denied the benefit of ITC to his customers by charging excess GST. Had he not charged the excess GST the customers would have less price while purchasing houses from the Respondent and hence above amount had rightly been included in the profiteering amount. The Profiteering amount could also not be paid from the GST deposited in the account of the Central and State Governments by the Respondent as the amount was required to be deposited in the CWFs as per the provisions of Rule 133 (3) (a) of the CGST Rules, 2017. Therefore, the contention of the Respondent was not sustainable. 8. Further, the DGAP's clarification dated 24.05.2022 were supplied to the Respondent and Applicant No. 1 to file their rejoinder. Vide his letter dated 06.06.2022, the Respondent has submitted his rejoinder against DGAP's clarifications wherein he has inter-alia, stated that without accepting the allegations made in the DGAP's Report and without prejudice to the submissions already made vide letter dated 27.04.2022, as an abundant pr....
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.... that if any reduction in the rate tax is ordered by the Central and the State Governments or a registered supplier avails benefit of additional ITC post-GST implementation, the same has to be passed on by him to his recipients since both the above benefits are being given by the above Governments out of their scarce and precious tax revenue. It also provides that the above benefits are to be passed on any supply i.e. on each product or unit of construction or service to every buyer and in case they are not passed on, the quantum of denial these benefits or the profiteered amount has to be computed for which investigation has to be conducted in respect of all such products/units/services by the DGAP. 12. The term 'profiteered amount' is clearly defined in the explanation attached to Section 171 of the CGST Act. These benefits can also not be passed on at the entity/organization/branch invoice/ business vertical level as they have to be passed on to each and every buyer at each product/unit/service level by treating them equally. The above provision also mentions "any supply" which connotes each taxable supply made to each recipient thereby making it evident that a suppli....
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....e of one real estate project, date of start and completion of the project, price of the flat/shop, mode of payment of price or installments, stage of completion of the project, rates of taxes pro and post GST implementation, amount of CENVAT credit and ITC available, total saleable area, area sold and the taxable turnover received before and after the GST implementation would always be different from the other project and hence the amount of benefit of additional ITC to be passed on in respect of one project would not be similar to the other project. Therefore, no set procedure or mathematical methodology can be framed for determining the benefit of additional ITC which has to be passed on to the buyers of the units. Moreover, this Authority under Rule 126 has been empowered to 'determine' Methodology & Procedure and not to prescribe it, Similarly, the facts of the cases relating to the sectors at Fast Moving Consumer Goods (FMCG), restaurant service, construction service, and cinema service are completely different from each other and therefore, the mathematical methodology adopted in the case of one sector cannot be applied to the other sector. Moreover, both the above benefits a....
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....nction, could not have been delegated to this Authority (an executive body). It is further submitted that delegation of such unabated and uncontrolled power to an executive body is itself unconstitutional. It is settled law that important legislative functions cannot be delegated. Further, where the delegation was arbitrary and without any guidelines or framework, the same has been held to be incorrect in law. In the context of the above contentions of the Respondent made in this para is not correct and it is submitted that the Parliament as well as all the State legislature, have delegated the task of framing of the Rules under the CGST Act, 2017 on the Central Government as per the provisions of Section 164 of the above Act. Accordingly, the Central Government in terms of Section 171 (3) of the CGST Act, 2017 read with Section 2 (87) of the Act ibid. has prescribed the powers and functions of the Authority, on the recommendation of the GST Council, which is a Constitutional federal body created under the 101st Amendment of the Constitution, as per Rule 127 and 133 of the CGST Rules, 2017. Further, the power to determine its Methodology & Procedure has been delegated to this Autho....
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....e Respondent. Hence, the judgment of the Hon'ble Supreme Court passed in the case of Indraprastha Gas Ltd. vs. Petroleum and Natural Gas Regulatory Board & Ors. 2015 (9) SCC 209 relied upon by the Respondent is of no help to him. Hence, the contention of the Respondent is not correct and not tenable. 19. The Respondent has submitted that the concept of GST being an indirect tax is an economic concept. A supplier cannot be mandated/ dictated through a taxing Statute to reduce the price to the same extent as benefit accrues due to the availability of ITC. In respect of the above contention of the Respondent, the Authority finds that Section 171 (1) of the CGST Act, 2017 provides that "Any reduction in rate of tax on any supply of goods or services or the benefit of the input tax credit shall be passed on to the recipient by way of commensurate reduction in prices." It is clear from a 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 m the rate of tax is effected by the Central or the State Governments or if a registered supplier avails the benefit of additional ITC the same have to be passed on b....
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....ed in the computation of profiteering as is the case of input services where the rate of tax on input services has increased from 15% to 18% at the tune of rollout of GST regime. In this context, this Authority finds that any additional benefit of ITC credit is required to be commensurately passed on to the flat buyers since the Respondent cannot be allowed to appropriate it illegally as the said benefit has been extended by the Government from the public exchequer. The Respondent has not paid even a single penny from his account and therefore, he cannot claim not passing on the benefit of additional ITC to the buyers as he has used the same in discharging his output tax liability. Therefore, the Authority finds that the above contention of the Respondent cannot be accepted. 22. The Authority finds that the Respondent has also contended that while arriving at the total alleged profiteering amount, a notional 12% amount of GST has been incorrectly added. The Respondent has submitted that the GST has already been deposited with the Government and hence it can not be held that the Respondent has profiteered from such an amount. In this connection, the Authority holds that the Respo....
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....et benefit of ITC with the introduction of GST. On this issue, it has been revealed from the DGAP's Report that the ITC as a percentage of the turnover that was available to the Respondent during the pre-GST period (April 2018 to June 2017) was 1.88% and during the post-GST period (July2017 to November 2020), it was 3.78% for the Project "Panchshil Towers". This confirms that post-GST the Respondent has benefited from additional ITC to the tune of 1.90% [3.78% (-) 1.88%] or his turnover for the said Project, and the same was required to be passed on to the customers/flat buyers/recipients. The DGAP has calculated the amount of ITC benefit to be passed on to all the flat buyers as Rs. 1,96,69,483/- for the Project 'Panchshil Towers' the details of which are mentioned in Annezure-14 of the Report. 25. For the reasons and discussions made hereinabove, the Authority finds no reason to differ from the above-detailed computation of profiteering in the DGAP's Report or the methodology adopted and hence, the Authority determines the profiteered amount for the period from 01.07.2017 to 30.11.2020, in the instant case, as Rs.1,96,69,483/- for the Project "Panchshil Towers'. This Authority....
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....Finance Act, 2019, and the same became operational w.e.f. 01.01.2O20. As the period of Investigation was 01.07.2017 to 30.11.2020, therefore, he is liable for imposition of penalty under the provisions of the above Section for the amount profiteered from 01.01.2020 onwards. Accordingly, notice be issued to him to explain why penalty should not be imposed on him. 31. The concerned jurisdictional CGST/SGST Commissioner is directed to ensure compliance of this order. It may be ensured that the benefit of ITC is passed on to each homo buyer customers/recipients as per Annexure- 'A' attached with this Order along with Interest @18% as prescribed, if not paid already. In this regard an advertisement of appropriate size to be visible to the public may also be published in a minimum of two local Newspapers/vehicular, press in Hindi/English/local language with the details i.e Name of the builder (Respondent) - M/s Panchshil Infrastructure Holding Pvt. Ltd., Poject- "Panchshil Towers", Location- Kharadi, Pune, Maharashtra and amount of profiteering i.e. Rs.1,96,69,483/- so that the concerned home buyers/customers/recipients can claim the benefit of ITC if not passed on Homebuyers/customer....
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....r the general law or Specific Laws whether condonable or not shall stand extended w.e.f. 15th March 2020 till further order/s to be 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, 27.04.2021, and 23.09.2021, it is directed that the period from 15.03.2020 till 28.02.2022 shall stand excluded for the purposes of limitation as may be prescribed under any general of special laws in respect of all judicial or quasi-judicial proceedings." Accordingly, this Order having been passed today falls within the limitation prescribed under Rule 133(1) of the CGST Rules, 2017. 35. A copy of this order be sent, free of cost, to Applicant No 1, the DGAP the Respondent, Concerned jurisdictional Commissioners CGST/SGST, the Principal Secretary (Town and Country Planning), Government of Maharashtra and Maharashtra RERA for necessary action. Encl:- Annexure - A (Pages 1 to 22). =....
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.... Ramnish Sharma 16,765,87 PATA0802 40 Mr. Chandrashekhar Khapre 16,765.87 PATA0903 41 Mr. Karim Kanji Samnani 16,957.82 M/s Lokmanya Multipurpose Co- PATD0901 16,826.42 42 22 op Soc. M/s Lokmanya Multipurpose Co- PATD0902 16,826.42 43 op. Soc. PATA1001 44 M/s Kish Handicrafts Pvt Ltd 16,886.96 PATA1002 16,886.96 45 Mrs. Minal Makar Ms. Advik Tecnocommercial Pvt PATA1004 16,725.74 46 Ltd PATD1001 16,886.96 47 Mr. Sameer Varma PATD1102 16.947.50 48 Mrs. Asha Kalantri PATA1201 49 Mr. Saket Sapra 17.008.04 PATA1203 50 M/s Filpak India Pvt Ltd 17.141.04 PATA1204 51 M/s Filpak India Pvt Ltd 17.141.04 PATE1103 52 Mr. Ankur Mantri 20,340.38 PATD0403 53 Mr. Riyaaz Makaney 15,113.40 PATA1603 17,385.33 54 Mr. Sunil Agarwal PATA1604 55 Mr. Anil Sakhi Thakur 17,385.33 PATA1703 56 Mrs. Nalini R. Shah 17,446.41 PATD0704 17.446.41 57 Mr. Shabbir Abdul Kader PATD1702 58 Mr. Shabbir S. Wakhariya 16.342.08 Case No. 62/2022 Sh. M.P. Keswani Vs. M/s Panchshi....
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....utubuddin 22,151.84 PATE1704 98 M/s Orbit Marketing Private Limited 22,224.30 PATE 1901 99 Mr. Milind Gokarn 22.221.85 PATE2304 100 Mr. Shekhar Jain 22,369.22 PATD1502 101 Mr. Sanjay K. Luthra 18,763.75 PATE1203 102 Mrs. Gira Dalal 22,586.59 PATA2404 103 Sai Indo Metal Resources Pvt. Ltd 19,095.40 PATE2504 104 Mrs. Prerana Dhawan 22.659.05 PATE2604 105 Mrs. Kavita Chawla 22.731.51 Mrs. Archana Dyaneshwar PATA2403 12,865.89 106 Pachundkar PATA3003 107 Mr. Shankar Narayan PATD3002 108 Mr. Rakhi Narendra Firodia 42,770.25 PATE0303 109 Mr. Babanrao Dagdu Shelke 21,209.88 PATE1502 110 Mr. Hemant Kesharchand Nahar 22.509.56 PATD1501 111 Mr. Manohar Sawilani 18,400.50 PATA2201 112 Mrs. Archana Bhutada 19,429.70 PATE1104 113 Mrs. Bijal Mehta 17,442.05 PATD1103 114 Mr. Prashant J. Keole 18.301.44 PATA2504 115 Mrs. Ripple Mirchandani 18.362.51 PATA1904 116 Mr. Nirmal V. Shah 17.084.85 PATA2701 117 Mr. Farook Merchant 19,127.00 PATA2602 118 Mr. Farook Merchant 19,06....
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....athi 22,725.34 PATB0903 158 Mr. Ankur Khurana 18,790.03 PATE2602 159 Mrs. Farnaz Jimmy Talati 22,725.34 PATE2302 160 Mrs. Rashida Lalji 19,057.09 PATB0403 161 Mr. Atul Sethi 17,629.63 PATB1803 162 Mr. Mukesh Agarwal 19,706.13 PATB1104 163 Mr. Mohinish Bhalerao 12.194.08 PATB1702 164 Mr. Manjeet Singh Chhabra 19,005.91 PATB1604 165 Mr. Nitin Nandial Lahoti 13,720.92 PATB1501 166 Mrs. Nimet Rashid Jaffer 19.005.91 PATE1503 167 Mr. Manpreet Singh 23,963.30 Dr. Yogesh Bharatbhushan PATE2502 22.653.41 168 Kshirsagar Mr. Satinder Luthra & Niranjana PATD1104 18,765.60 169 Bhatti PATE1702 22.797.26 170 Mr. Milind Mukewar PATE1002 171 Mrs. Kavya Sanjay Ahuja 23,013.04 PATA2604 19,217.54 172 Mr. Gurshaan Singh Anand PATE 1902 173 Mr. Shirazali Dharamshi 23,660.38 PATE2704 174 M/s GA Design Consultants LLP 17.152.21 PATD1601 175 Mr. Dishan Kamdar 18,461.04 PATD2703 176 Mrs. Sejal Kamdar 18,057.14 PATB0301 177 Mrs. Pooja Nilesh Pandharkar 9.837.74 PATE0902 178 Mrs. R....
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....eji Billimoria 23,731.43 PATD1404 218 Mr. Yogesh Shah 20,296.44 PATA2104 219 Mrs. Yeshoda Narayan Poojari 14,491.68 PATB1703 220 Mr. Kumar H. Jagtiani 20,377.94 PATE2103 221 Mr. Jehangir Jehangir 24.195.36 PATE2603 222 Mrs. Jasmine Jehangir 23,934.32 PATD1202 223 Mr. Adit Sanjay Raja 11.559.30 PATD1204 224 Mr. Neil Paresh Raja 11,644.42 PATD0603 225 Mr. Rahul Deelip Sankhala 19.539.30 PATC2703 226 Ms. Kavita Jinesh Sonawala PATC2704 227 Mr. Ritesh Gautam Gandhi PATC0903 228 Ms. Dilkash Falahati PATC1303 229 Mr. Sanjeev S. Kharkar PATD2502 230 Mr. Shailesh Parekh 14.162.58 PATB2703 231 Mr. Chinmay Sunil Garde 19.889.35 232 Mr. Mohan Kumar Gannavaram Venkatesh PATE2001 22,412.10 PATF0704 233 Mr Vilas Raghunath Kulkarni 55.926.50 PATD1703 234 Mrs. Shaila Rajendra Mayur 17,446,41 PATE2401 19,704.43 235 Ms. Priti Aggarwal PATB2004 N 236 Mr. Kartik Joshi 15,627.39 PATD2002 15,511.42 237 Mr. Nikhil Thakur PATF2104 238 Mr. Parikshit Anil Shahani 61.737.54 PATD....
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..... Bankelal Ramswarup Goyal PATD1101 16.947.50 279 (HUF) PATE1301 280 Mr. Vijay Dattu Lande 19,214.24 PATE2801 281 Mr. Jitender Singh Ahluwalia 42,517.01 PATD1002 282 Mrs. Ranjana Popat 19,066.45 PATA1802 283 Mr. Drumil Gandhi 19,490.25 PATD2203 284 Mr. Amit B. Merchant 19,217,54 PATC2004 285 Mrs. Rohini Ramesh Kulkarni PATF0903 50,882.87 286 Mr. Bibhu Prasad Bhuyan PATF1104 287 Mr. Yogesh Dattatraya Wagh 64,040.30 Mr. Capt. Christopher Stephen PATC1001 288 Verma PATC1203 289 Mr. Viren Joshi. PATC2602 290 Mrs. Anita Mamidwar PATE2202 291 Mrs. Smita Ravichandran lyer 18.122.05 PATA0102 292 Mr. Ramesh Mani 41,557.71 PATE2701 26,292.89 293 Mr. Amit Tiwari PATD1804 17.507.48 294 Mr. Jeevan J. Bhonsale PATD0401 295 Mr. Chetan Chordia 9.171.79 PATD0701 19.127.00 296 Mr. Sam Buhariwala PATD0502 297 Mrs. Kavita Girish Maindakar 13,801.89 PATD0602 13.864.35 298 Dr. Saroj Santosh Kavthale PATF0604 299 Mr. Pawan Saraogi 54,359.33 r PATD0102 300 Mrs. Jayanthi Ra....
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.... 255,948.62 PATG2503 340 Ms. Neha Joshi 255.948.62 PATE1503 59,289.01 341 Mr. Ranjan Lath PATF1504 59,289.01 342 Mr. Amitabh Sarkar PATH0704 343 Mr. Vimal Gupta 241,456.49 344 Mr. Rajesh Bhojwani PATG1503 247,897.43 PATG1103 244.676.96 345 Mrs. Mumtaz Jaria PATH0403 346 Mr. Aaftab Iqbal Shaikh 239,041.13 PATG0403 347 Mr. Sujay Vijay Tambaku 239,041.13 PATF1403 60.426.69 348 Mr. Manish Gupta PATG2501 255,948.62 349 Mr. Kartik Anand PATG2404 255,143.50 350 Mr. Kartik Anand PATH1701 351 Mrs. Mahtani Kamlesh Mohan 249,515.53 PATG1802 250,312.79 352 Mrs. Rasika Malkan PATG1702 249,507.67 353 Dr. Aakash Shah PATH0304 238,236.02 354 Mr. Harish B Halan PATH1403 355 Ms. Rakhi Shetty 257,573.09 PATG1504 247.897.43 356 Ms. Neeti Jethlia PATG0703 241.456.49 357 Mr. Ashish S. Deshpande PATH1503 211,057.18 358 Mr. Rustom Adi Contractor PATH1404 257,573.09 359 Ms. Pushpa Kushal Hegde PATG1603 360 Mr. Jayant K. Dayalani 248,702.55 N PATG1604 361 Mr. Jayant K. Day....
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.... Chandrashekhar PATG1404 408 Deshpande PATB0504 409 Mr. Rahul Nayak PATG1003 410 Mr. Vikas Sarraf PATG0704 411 Mr. Pundlik Bapurao Turkhade PATH1204 412 Mr. Mohit M R Rangwani PATD2904 413 Ms. Swati Sadineni PATH0404 414 Mr. Nester Agnelo Fernandes PATH1704 415 Ms. Muneera M. Tarwalla PATG2502 416 Mrs. Joanna N. Mankad PATH1203 417 Ms. Noopur Varshney PATH1003 418 Ms Niharika Varshney PATG0804 419 Mrs. Seema Jaiswal 420 421 M/s Exadatum Software Services PATE2803 Pvt Ltd M/s Exadatum Software Services PATE2903 Pvt Ltd 422 M/s Exadaturn Software Services Pvt Ltd PATE2904 PATH1401 423 Mr. Aniruddha A. Deshpande PATG1001 424 Mr. Simran Wadhwa PATH1302 425 Mr. Rajendra Ranjit Todkar PATG0802 426 Mr. Rajnesh Kathuria PATG0401 427 Mr. Abhijit Dayal Case No. 62/2022 Sh. MP. Keswani Vs. M/s Panchshil Infrastructure Holding Pvt. Ltd. Page 14 of 22 PATG2202 428 Mr. Mrunal Subhash Shetye PATF2001 429 Mr. Niraj Kumar PATD2304 430 Mr. Rajan Gupta PATG2702 431 Ms. Ferzeen Hoshang Cha....
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....2702 485 Mr. Satish Mohan Shinde PATE3003 486 Mr. Ajayrao Nanasaheb Jadhavrao PATE1202 487 Mrs. Ashwini Yogesh Dhongade PATH1002 488 Mr. Shashank Rai PATD2003 489 Mr. Ashish Gupta Case No. 62/2022 Sh. M.P. Keswani Vs. M/s Panchshil Infrastructure Holding Pvt. Ltd. Page 16 of 22 PATE1101 490 Mr. Dinesh Kapildev Sharma PATB0702 491 Ms. Anuja Abhay Mutha PATH2203 492 Mr. Umesh Vitthal Madhure PATG2304 493 Mr. Anant Anandrao Meghe PATF0804 494 Mr. Eyzadpur Tirandaz Faridani PATF2003 495 Mr. Eraz T. Faridani PATD2604 496 Mr. Anil Kapur PATH0402 497 Mr. Alankrit Atal PATG0801 498 Col. Monish Gaur PATH1801 499 Mr. Rony Kurian Aluckal PATD1304 500 Mr. Sanjay Sharad Jagtap PATH2204 501 Mr. Rahul Arora PATE0701 502 Mr. Siddharth Narayan PATH2001 503 Mr. Subir Dhawan PATH0502 504 Mr. Ajay K. Subramaniam PATH0602 505 Mr. Shalini Mangal PATH0801 506 Mr. Mohit Jain PATH2004 507 Mr. Sunil Trehan N 508 Mr. Venkata Kalyan Kumar Yadalam PATH0401 PATG1704 509 Mr. Kulbir Singh Mann PATG1302 510 Mr.....
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....hant Agarwal PATE2804 561 Mr. Karan Ramesh Kapoor PATH1904 562 Mrs. Savita Maruti Kalyankar PATE1403 563 Mr. Sivakumar Kulathumani lyer PATE2204 564 Mr. Vikas J. Bansode PATE2003 565 Mr. Jeetendra Singh J Saluja PATA0501 566 Mr. SMPN Singh Shahi PATF2803 567 Mr. Siddharth Panda PATH2304 r 568 Mrs. Swati Mishra PATA0901 569 Mrs Usha Chanadrakumar Mani PATG2603 570 Mr. Abhinav Srivastava PATG2102 571 Mr. Rishish Kumar PATE1201 572 Ms. Savita Sunil Jerath PATH2801 573 Mrs. Abhilasha Rajesh Bhojane PATB0704 574 Mr. Amit Tare PATH2303 575 Mr. Samarjeet H. Gandhi PATA1301 576 Mrs. Sanjivani Vilas Raut PATE0601 577 Mr. Rohit Kumar Ashokrao Patil PATHC201 578 Mr. Surbhit Rai PATC0703 579 Mrs. Rashmi Vivek Gupta PATC0403 580 Mrs. Shashi Gupta PATH0302 581 Mr. Saeed Khaled Malkani Case No. 62/2022 Sh. M.P. Keswani Vs. M/s Panchshil infrastructure Holding Pvt. Ltd Page 19 of 22 PATA2804 582 Mr. Sham Laxmikant Choudhari PATG2902 583 Mrs. Shyama Desal PATA0701 584 Mr. Sandeep Chhabra PATH2701 585 ....