Shri Rahul Sharma, Director General of Anti-Profiteering, Indirect Taxes & Customs Versus M/s. Cloudtail India Pvt. Ltd.

2019 (3) TMI 430 – NATIONAL ANTI-PROFITEERING AUTHORITY – TMI – Profiteering – printing cartridges – benefit of reduction in the GST rates not passed on – section 171 of the CGST Act, 2017 – Held that:- It is clear that anyone alleging profiteering can file a complaint. So it is not necessary that the complainant has to purchase the products, Moreover, all the details are available so the question of not considering the compliant do not arise at all. Even the MRP that is manually written happens to be correct MRP as admitted by the respondent. Therefore, the Standing Commitee has rightly forwarded the same the DGAP and the DGAP has accordingly completed its investigation and filed his report.

In the present case, we are concerned with the supplier and the supplier is the respondent who has increased the price even after reduction of GST rate of tax. The passing of the benefit by the distributor or retailer does not rest on the fact that the manufacturer or his supplier should ha

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SHAH, TECHNICAL MEMBER Present:- Mr. Rahul Sharma and Mr. Sachin Taparia for the Applicant No. 1. Ms. Gayatri Verma, Deputy Commissioner, DGAP for the Applicant No. Ms. Sheena Saveen Sr. Manager, Deloitte, Mr. Ankit Mundra Sr. Tax Manager, Cloudtail India Pvt. Ltd., Mr. Mahesh Jaisraj CA Partner, Deloitte, and Ms. Sangita Prakash CA Manager, Deloitte for the Respondent. ORDER 1. The brief facts of the case are that under Rule 128 of the CGST Rules, 2017, a complaint dated 17.05.2018 was filed by the Applicant No. 1 against the Respondent before this Authority alleging that the Respondent had not passed on the benefit of reduction in the GST rate applicable to the printing cartridges (HSN 8443) from 28% to 18% w.e.f. 15.1 1.2017 and had increased their base price, therefore there was no reduction in the price (inclusive of GST @ 18%) charged from the recipients. In support of his allegation, the Applicant No. 1 had submitted copies of the two sale invoices of HP 678 L0S24AA Combo Pack I

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itted that the benefit of reduction in the rate of tax had not been passed on to the recipients by way of commensurate reduction in the price. The Respondent was also asked to suo-moto determine the quantum of benefit not passed on, if any, and indicate the same in his reply to the notice. The DGAP sought extension to complete the investigation, which was extended upto 07.10.2018 by this Authority vide order dated 07.09.2018 in terms of Rule 129 (6) of the CGST Rules, 2017. 4. The DGAP has also stated that, in response to the notice the Respondent vide letter dated 06.08.2018 submitted that he was a retailer and sold the products manufactured by other vendors; that he had no control over the MRP affixed by the manufacturer/ importer; that the manufacturer/ brand-owner (HP) had changed the MRP during the period between July 2017 to December 2017, that HP had first increased the MRP on account of increase in the tax rate from 5% (VAT) to 28% (GST) and also on account of imposition of Cus

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of discount would not amount to profiteering. 5. The DGAP has also informed that the Respondent had submitted the following documents: List of all GST registrations. Details of invoice-wise outward taxable supplies of the said product (other than zero rated) from 01.11.2017 to 31.07.2018 along with certified summary of the same. Copies of GSTR-1I and GSTR- 3B for the period November, 2017 to July, 2018. Copies of two sample sale and purchase invoices of the goods under investigation for the period from July, 2017 to July, 2018. The Respondent also submitted that they had not purchased this product after December, 2017. 6. The DGAP in its report has further informed that during the period between 01 .10.2017 to 31.12.2017, the Respondent had sold 16,248 units of the above product whereas the sales figure had dropped to only 251 units during the period from January, 2018 to July, 2018. An e-mail dated 06.09.2018 was sent to the Respondent by the DGAP to indicate the reasons behind such

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period 01 .10.2017 to 14.11.2017) to ₹ 887.90 (average base price for the sales made during the period 15.11.2017 to 31.07.2018). The Report has also noted that the two invoices referred above showed that the Respondent had offered similar discount of 5%, as earlier, on the increased base price after GST rate reduction w.e.f. 15.1 1.2017. Thus, by increasing the base price of the said goods and also by increasing the cum-tax price charged from the recipients post GST rate reduction, the benefit of GST rate reduction was not passed on by the Respondent to the recipients. 8. The DGAP's Report has also stated that the profiteered amount during the period w.e.f. 15.1 1.2017 to 31.07.2018 came to ₹ 10,79,813.28 The details of which are furnished in the table below:- Product Sales 01.10.2017 to 14.11.2017 (GST@28%) during Sales during 15.11.2017 to 31.07.2018 (GST@18%) Commensurate Price Profiteering (Rs.) Total Profiteering Avg. Base after Discount (Rs.) Qty. Sold Avg. Base

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2018 Mr. Rahul Sharma and Mr. Sachin Taparia appeared on behalf of the Applicant No. 1 while the DGAP was represented by Ms. Gayatri Verma, Deputy Commissioner, and the Respondent was represented by Ms. Sheena Saveen, Sr. Manager Deloitte, Mr. Ankit Mundra, Sr. Tax Manager Cloudtail India Pvt. Ltd., Mr. Mahesh Jaisraj CA, Partner Deloitte and Ms. Sangita Prakash CA, Manager Deloitte. On the request of the Respondent, further hearings were granted on 26.11.2018 and 05.12.2018. 11. The Respondent has filed detailed written submissions on 22.11.2018 and 29.11.2018. In his submissions dated 22.11.2018, referring to the DGAP Report, the Respondent has submitted that he had already filed his reply vide his letter dated 06.08.2018 before the DGAP. In addition, he had made the following submissions with respect to the Report submitted by the DGAP. He has claimed that the DGAP has framed the Report on certain assumptions which were incorrect and several key aspects and facts having bearing on t

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application is given below: 13. The Respondent has also stated that in the Letter sent to the Members of the Standing Committee on Anti-Profiteering by the Secretary (NAA) vide his letter 22011/NAA/20/2018/122, dated May 18, 2018, this fact had been reconfirmed. The Respondent has also enclosed extract of the relevant portions of the letter which is reproduced below:- Sub – Information received by NAA regarding profiteering by HP Printer- reg. Please find attached herewith a complaint against HP printers regarding increase in unit price of HP Printer canridge (via Amazon) having the unit price as ₹ 688/- on 4.10.17 and after GST reduction from 28% to 18% unit price on 09.12.2017 was ₹ 911/- 14. He has also claimed that in the Minutes of the Standing Committee Meeting held on May 25, 2018, the application filed against M/S HP Printers has been discussed and forwarded for further investigation although the above Applicant had not made any specific allegations against the Resp

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8.00 Actual price difference (42.59) 68.27 Price difference % on sales price (6.51%) 7.88% Price difference % on MRP (3.96%) 5.90% *Exclusive of GST/ taxes 15. The Respondent referring to the two invoices (shown in the table given above) filed by the Applicant No. 1 has also claimed that he had no control over the MRP affixed by the Brand owner i.e. HP India and he was just a retailer dealing with the products manufactured or imported by the brand owner. He has further claimed that the product in question had not been imported by him. Quoting the circulars of the Legal Methodology department, he has claimed that as per the provisions of the Legal Metrology Act, 2009, it was the duty of the manufacturer/ importer to determine the MRP and to affix MRP label on the products. He has further submitted that the MRP of the product was changed by HP India the brand owner on two occasions. The MRP was ₹ 1076 upto 30th June 2017 (pre-GST), from 01.07.2017 to 14.11.2017 the MRP was increase

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as well. He has further claimed that the Applicant No. 1 must have purchased the product only when the MRP of the product was ₹ 1,076 and subsequently when it was revised to ₹ 1,158 and there did not seem to be a purchase made by the Applicant when the MRP was increased to ₹ 1,239. Thus, the Applicant was unaware of the fact that there was an increase in the post-GST MRP and the sale price by HP India to ₹ 1,239 and this fact was ignored by the DGAP in his Report in spite of furnishing a certificate obtained from the brand owner about change in MRP. He has also furnished the details of pre and post GST MRPs as under:- Particulars Pre-GST Post-GST (w.e.f. 01.07.2017) Post-GST (w.e.f. 15.11.2017) Basic Customs Duty – 5% 5% Countervailing duty ( CVD ) 10%* – VAT 5% – GST – 28% 18% Effective pre-GST incidence of taxes 15.5% – Effective post-GST incidence of taxes – 34.4 23.9 Change in effective rate 18.9% (10.5%) MRP of product** 1,076 1,239 1,158 16. The Respondent

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he also submitted that in compliance with the anti-profiteering regulations, the brand owner, HP India had reduced the MRP of the product from ₹ 1,239 to ₹ 1,158, post the reduction in the rate of tax in November 2017. He has also emphasised that at no given point of time the Respondent had sold the above product at a price more than the reduced MRP of ₹ 1,158 after 14.11.2017. He has also further claimed that because of voluntary, non-binding discounts to the customers for various business reasons, the Respondent had continued to sell his product to his customers at a price lower than the reduced MRP. Based on the above facts the Respondent has claimed that he had not profiteered since the actual price of the product was well below the entitled margin. He has further claimed that discounts was his prerogative as had been decided by the Authority in the case of Flipkart (Case no 5/2018 dated July 18, 2018) = 2018 (7) TMI 1490 – NATIONAL ANTI-PROFITEERING AUTHORITY whe

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tted that at the time of transition into GST, the a stock of 1 ,067 units of the product as of July 1, 2017 and similarly HP India as well as the distributors i.e. M/s. Savex Technologies Private Ltd. and M/s. Compuage Infocom Limited would have had stock bearing pre-GST MRP of ₹ 1,076. Though the MRP was increased by the HP India from ₹ 1,076 to ₹ 1,239 on the implementation of CST on July 1, 2017, it normally took about 3-4 months for the product imported to move from HP India to the Distributors and then to the retailers to be sold finally to the end customer through the supply chain. Further, the Respondent had submitted that he had purchased 23,307 units in the month of July 2017 and August 2017 from Savex Technologies Private Ltd. and Compuage Infocom Limited at ₹ 696.78 and there was no purchase post August 14, 2017 and before the date of sale, i.e., October 4, 2017. The above two companies had stocks of the products as of July 1, 2017 which were sold to

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to ₹ 1,239 effective July 1, 2017, the continued to receive the pre-GST imported stock for a period of another 45 days and he had taken another 3 to 4 months to liquidate the opening stock as well as the purchases of pre-GST and post GST imported stock. He has further justified the fact that the Respondent had sufficient pre-GST MRP stock when the supply was made to the above Applicant by providing the stocks available with him at different points of time as is given below in the table:- Particulars Quantity Opening stock as on July 1, 2017 1,067 Quantity purchased between July 1, 2017 to August 14, 2017 at ₹ 696.98 (combination of pre-GST MRP and post-GST MRP stock) 27,625 Quantity sold upto September 30, 2017 (net of sales returns) (17,064) Stock as on September 30, 2017 11,628 Supplies made between October 1, 2017 to October 4, 2017 including supplies to the Applicant 1,166 19. He has also claimed that the above Applicant was unaware that the product sold to him during A

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798 2,013 Sales made in November 2017 (net of sales returns) (4,613) Stock as on November 30, 2017 2,899 Supplies made from December 1, 2017 to December 9, 2017 including supplies to the Applicant 753 Thus, it has been contended that because the Applicant No. 1 did not make any purchase of product with MRP of ₹ 1,239, it appeared to him that there had been an increase in the MRP. However, the fact was that the MRP had been reduced from ₹ 1,239 to ₹ 1,158. He has also produced the details of purchases as given below to substantiate his claim which is authenticated with the CA certificate. Amount in Rs. Period Total purchase cost (excluding taxes) Qty purchased Purchase price per unit* (B) (C) D = (B)/(C) July 1, 2017 to August 14, 2017 1,92,39,708 27 ,625 696.46 October 31, 2017* 6,96,460 1,000 696.46 October 25, 2017 to December 14, 2017 25,59,186 3,207 798.00 2,24,95,354 31,832 *Purchase on October 31, 2017 is pertaining to a one-off single invoice for purchases made

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n account of increase in BCD and transition stock credit benefit of CVD being passed on as per Section 140 (3) of the CGST Act, 2017. It is normal for large organization to revise their selling price to reflect such changes only on fresh stock imported/ manufactured post the rate changes and not in respect of the stock existing in the supply chain and that was probably why the purchase price was increased post mid-August 2017 as opposed to July 1, 2017 itself. 21. The Respondent has further submitted that depending upon various factors like festival sales, inventory position, competitor strategy, market penetration, customer loyalty or other similar business reasons, he had decided not to sell the product on its MRP and provided voluntary discounts/benefits to his customers for a particular duration of time. These benefits were discretionary and he was not under any statutory obligation to provide them or to withdraw them. He had analysed the price difference of the product sold to the

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0% Entitled margin 144 183 Entitled margin % on MRP 13.40% 15.83% *Price difference is solely the difference in the sale price and purchase price. This is before factoring other direct and indirect expenses. ***ExcIusive of GST/ taxes Note 1 – Invoice issued against order dated September 23, 2017 – During the Great Indian Festival sale – wherein the company gives additional discounts Note 2 – Invoice issued against order dated December 6, 2017 – During normal sales wherein discounts are offered at lower levels Actual average Price difference on sales post November 15, 2017 Amount in Rupees Particulars Amount Average selling price including taxes post-rate change (as arrived in the report based on sales made for the period November 15, 2017 to July 31, 2018) 1,047.72 Less: Taxes (GST @ 18%) 159.82 Average selling price excluding taxes 887.90 Purchase price 798.00 Price difference 89.90 Price difference % of selling price 10.3% 22. The Respondent has also stated that in the retail indust

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rofiteering would be grossly incorrect. Entitled Margin Amounts in Rs. Particulars Post GST (July 1, 2017) Post rate change (November15, 2017) MRP 1 ,239.00 1,158.00 Price without tax 967.97 981.36 Procurement price 798.00 798.00 Entitled margin 169.97 183.36 Entitled margin % of MRP 14% 15.83% Entitled margin % on selling price 17.56% 18.68% 23. The Respondent has also re-iterated that the invoices under consideration in the notice had been raised under two different circumstances. While the first invoice dated 04.10.2017 reproduced below was raised during the festive promotion sale, the other has been raised during a period where he was operating at business as usual . The invoice under question pertained to the sale made by him during a promotional event run by Amazon, which was conducted between September 21, 2017 and September 24, 2017. The invoice provided by the above Applicant had clearly captured the order date as September 23, 2017, which fell within the duration of the Great

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should consider the fact that on an online marketplace where it was common practice to issue discounts, the fact that the product was a discounted one should not be ignored. 25. It is also submitted that the procurement price had increased from ₹ 696 to ₹ 798 in the month of October 2017, and if the Respondent had continued to sell at the average base price of ₹ 705.90, as envisaged by the DGAP, he would have incurred a loss. For the 5,028 units sold by him during the period November 15, 2017 to July 31, 2018, they would have incurred a loss of ₹ 4,62,576 as could be seen from the table below:- Amount In Rs. Particulars Amount Average base price pre-rate change (as arrived in the report based on sales made for the October 1, 2017 to November 14, 2017) 705.90 Purchase price 798.00 Margin (92.00) 26. He has also submitted that the DGAP had ignored the fact that the copy of the application filed along with the copies of the invoices, made available to him, did not

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ded to pursue the application further. This submission made by him to the reply to the notice issued by the DGAP had been ignored in the Report. 27. He has further submitted that the Report has erred in the methodology adopted for computation of the profiteering amount. He has further submitted that the average base price per unit for the period prior to the rate change had been computed based on the sale data for 1.5 months alone. The amount has been arrived at based on sales details for the period October 1, 2017 to November 14, 2017 alone, as could be seen from the table given below. Instead the average base price per unit for the period prior to the rate change should have been calculated on all the sales made from July 1 , 2017 to November 14, 2017. The average base price per unit in respect of sale of the product from July 1, 2017 to November 14, 2017 was ₹ 710.78 and not 705.90, as has been stated in the DGAP Report and out of the 5,028 units sold between November 15, 2017

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eering Average base price after discount Qty. Sold Average base price after discount Qty. Sold Actual selling price B C D E F=118% of D G-118% of B H=[F-G] 705.90 11471 887.90 5028 1047.72 832.96 214.76 28. The Respondent has contended that the profiteered amount should be calculated on the basis of the difference between the commensurate base price and the average base price after discount without considering the tax element as the differential tax element has anyway been deposited by him with the Government on a monthly basis as had been declared in the GST returns. Instead the formula in Column H should have been H=D-B instead of H=F-G . Further, it has been submitted that the Report had not considered the sales returns. If all these submissions were considered, he has claimed that the amount profiteered, if any, should be restricted to ₹ 7,82,425.60. The revised amount as given in Table B with the exact amount of profiteering is shown below:- 1. Reduction in amount profiteere

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iteered 9,15,096.00 8,91,263.28 *Based on sales made between November 15, 2017 to July 31, 2018 **Based on sales made between October 1, 2017 to November 14, 2018 ***Based on sales made between July 1, 2017 to November 14, 2018 3. Reduction in amount profiteered after considering sales returns Amount in Rs. Particulars Amount Amount Average base price per unit after discount* (A) 887.90 887.90 Average base price per unit after discount** (B) 710.78 710.78 Profiteering per unit 177.26 177.26 Quantity sold 5,028 4,414 Total amount profiteered 8,91,263.28 7,82,425.60 *Based on sales made between November 15, 2017 to July 31, 2018 * *Based on sales made between July I, 2017 to November 14, 2018 Rectified table as provided by the Respondent Product Sales during 1.10.17 to 14.11.17 (GST @28%) Sales during 15.11.17 to 31.07.18 (GST@18%) Commensurate price Profiteering Total profiteering (Rs.) Average base price after discount Qty. Sold Average base price after discount Qty. Sold Actual sellin

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rding the MRP of the product in the complaint while the MRP had been manually mentioned, after confirming that the Applicant was not a purchaser of the goods. He once again emphasised that Section 128 required every Application filed must be complete in all respects. An application filed without sufficient proof or purchase could not be considered a valid application. In the current proceedings, the Application filed was with respect to an alleged increase in MRP of the product. He has also submitted that the above Applicant neither in the complaint nor during the hearing has provided any proof regarding the MRP which he had disputed. The Applicant had merely manually mentioned the MRP after confirming that he had not even purchased the goods. The Respondent has also reproduced the extract of the sale details (reproduced below) where manual MRP has been mentioned and stated that the details of the order placed, pack shot etc. were key factors to determine the facts of the case. 30. He

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as made out. b. With regard to the Respondents submission that the applicant had not provided any proof regarding the MRP of the product disputed in the complaint and that MRP had been manually mentioned, even after confirming that the applicant isn't a purchaser of the goods, the DGAP quoting Rule 129 (1) of the CGST Rules, 2017, has stated that the present complaint was examined by the Standing Committee in its meeting held on 25.05.2018, wherein the complaint was found fit for investigation and it was decided to forward the same to the DGAP for investigation. c. The complainant had enclosed copies of invoices issued by the Respondent since the transaction invoice was issued by M/s. Cloudtail India Pvt. Ltd., the investigation was carried out against the Respondent. With regard to the issues that MRP was decided by the brand owner and there had been change in MRP post GST implementation, the DGAP submitted that the profiteering has been calculated on the transaction value (after

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m ₹ 705.90 (average base price for the sales made during the period 01.10.2017 to 14.11.2017) to ₹ 887.90 (average base price for the sales made during the period 15.11.2017 to 31.07.2018). He has also stated that it was the Respondent's own statutory responsibility and obligation to pass on the benefit of reduction in the GST rate to his customers and the Respondent was required to sell the said goods at the pre 15.11.2017 base price and charge lower GST @ 18% on such base price. He has also mentioned that the issue of change in MRP was not taken into consideration for profiteering calculation. e. With regard to the issue that the average base price per unit for the period prior to rate change should have been considered based on sales data for the period 01.07.2017 to 14.1 1 .2017, the DGAP has submitted that Section 171 (1)of the Central Goods and Service Tax Act, 2017 required that a reduction in rate of tax on any supply of goods or services or the benefit of input

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revision) could not be determined. 32. We have considered the Report of the DGAP and the submissions made by the Respondent and other materials placed on record. The mandate of the Authority as per Section 171 of the CGST Act, 2017 read with Rule 127 of the CGST Rules, 2017 is to examine and determine as to whether- i) any reduction in rate of tax on any supply of goods or services or the benefit of ITC has been passed on to the recipient by way of commensurate reduction in prices, ii) to identify the registered person who has not passed on the benefit of reduction in the rate of tax on supply of goods or services or the benefit of ITC to the recipient by way of commensurate reduction in prices. 33. The Respondent has raised the following objections on the complaint itself which are being dealt in the following paras:- (i) Firstly, the Respondent, as discussed in para 12 to 14 above, has submitted that the proceedings initiated should be deemed infructuous as the complaint under Secti

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al purchaser and the claim of the Applicant stands invalidated as crucial details were missing and the MRP was also written manually. Rule 128 (2) of the CGST Rules, 2017, reads All applications from interested parties on issues of local nature shall first be examined by the State level Screening Committee and the Screening Committee shall, upon being satisfied that the supplier has contravened the provisions of Section 171, forward the application with its recommendations to the Standing Committee for further action . Further Rule 137 (c) of the CGST Rules reads that interested party includes- a. suppliers of goods or services under the proceedings; and b. recipients of goods or services under the proceedings; c. any other person alleging, under sub-rule (1) of rule 128, that a registered person has not passed on the benefit of reduction in the rate of tax on any supply of goods or services or the benefit of input tax credit to the recipient by way of commensurate reduction in prices.

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by Section 171 of the CGST Act, 2017, to pass on the benefit of reduction in tax. In the present case, we are concerned with the supplier and the supplier here is the Respondent who has increased the price even after reduction in the GST rate of tax. The passing of the benefit by the distributor or retailer does not rest on the fact that the manufacturer or his supplier should have passed on the same benefit to him first. 36. The Respondent has further alleged that when the two invoices filed by the Applicant were compared, it appeared that the Applicant must have purchased the product only when the MRP of the product was ₹ 1,076 and subsequently, when it was revised to ₹ 1,158 and it seemed that there was no purchase made by the Applicant when the MRP was increased to ₹ 1,239. Thus, the Applicant was unaware of the fact that there was an increased post-GST MRP and sale price by HP India to ₹ 1,239 and this fact was ignored by the DGAP in his Report. Therefore,

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This statistics itself clearly shows that when the MRP reduced from ₹ 1 , 239 to ₹ 1,158, the procurement price remaining the same and with GST rate of tax being reduced from 28% to 18%, the Respondent had increased his selling price by ₹ 13.39 per unit and on this increased price GST of 18% has also been collected. As claimed by the Respondent he could not take advantage of the reduction in the rate of tax to increase his profit margins. The benefit of reduction in rate of tax has to be necessarily passed on to the recipients. Moreover, the DGAP has rightly taken the transaction value of the supplier which was the price that was charged by the Respondent from his recipients which excluded the impact of discounts. 37. The Respondent has further submitted that there had been an increase in the procurement price after introduction of GST with rate of tax being 28% on the products in question. The rate of change of tax from 28% to 18% had been w.e.f. 15.11.2017. Therefor

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hence the contention of the Respondent made in this behalf cannot be accepted. With regard to the sale returns of 614 units the Respondent has not filed any documentary proof to show that these units were supplied and returned during the period in question. Hence, the benefit of these units cannot be extended. 38. The contention of the Respondent that the DGAP has arrived at the profiteered amount by taking into account the cum tax prices and he should have taken the average base price without tax since the tax amount had already been paid to the Government, does not hold good as already discussed, the Respondent has not only increased his base price but has also collected GST on the increased base price. The recipient has to be given the benefit of the increased base price and the increased tax collected from him. Therefore, the profiteered amount is arrived at as shown in the table below. Product Sales during 01.07.2017 to 14.11.2017 (GST @28%) Sales during 15.11.2017 to 31.07.2018 (

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of ₹ 10, 79,813.28 in the Consumer Welfare Fund of the Centre and the respective States as per the provisions of Rule 133 (3) (c) of CGST Rules, 2017. Further the Respondent is directed to deposit the above amount as per the provisions of Rule 133 (3) (c) in the ratio of 50:50 in the Central and the State Consumer Welfare Funds. Accordingly the Respondent is directed to deposit an amount of ₹ 5,39,906.64 in the Central CWF and the balance in the State CWFs as given below. The above amount shall be deposited within a period of 3 months from the date of receipt of this order. S. No State Qty Nos. Profiteering per Unit Profiteering by the states Rs. 1 Andaman & Nicobar 3 214.76 322.14 2 Andhra Pradesh 75 214.76 8053.50 3 Arunachal Pradesh 3 214.76 322.14 4 Assam 16 214.76 1718.08 5 Bihar 27 214.76 2899.26 6 Chandigarh 18 214.76 1932.84 7 Chattisgarh 15 214.76 1610.70 8 Goa 41 214.76 4402.58 9 Gujarat 165 214.76 17717.70 10 Haryana 283 214.76 30388.54 11 Himachal Pradesh 1

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