Additional input tax credit benefit was not established where post-GST credit ratio declined and transitional VAT credit was inapplicable.

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....Section 171(1) requires suppliers to pass any additional input tax credit arising from GST implementation to recipients through a commensurate price reduction. Project-specific CA-certified data was accepted because statutory records consolidated figures across projects and could not provide a project-wise split. The post-GST ratio of credit availed to purchase value had declined, showing that no additional input tax credit accrued. Transitional VAT credit passed to eligible purchasers did not concern the applicant, whose agreement was executed after GST implementation and for whom no corresponding VAT credit arose. The DGAP report was accepted and profiteering was not established.....