Shri Rahul Sharma, Director General of Anti-Profiteering, Indirect Taxes & Customs Versus M/s. Cloudtail India Pvt. Ltd.
GST
2019 (3) TMI 430 – NATIONAL ANTI-PROFITEERING AUTHORITY – TMI
NATIONAL ANTI-PROFITEERING AUTHORITY – NAPA
Dated:- 7-3-2019
Case No. 16/2019
GST
SH. B. N. SHARMA, CHAIRMAN, MS. R. BHAGYADEVI, TECHNICAL MEMBER, MR. AMAND 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
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said product had been passed on by the Respondent to his customers or not.
3. The DGAP after completing the investigation has submitted his report under Rule 129 (6) of the CGST Rules, 2017 on 19.09.2018. The Report states that a notice under Rule 129 of the CGST Rules, 2017 was issued on 10.07.2018, calling upon the Respondent to submit his reply as to whether he admitted 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 th
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invoice dated 09.12.2017 was raised during the course of routine business, when there was no promotion and no exceptional discounts were offered, that the margin earned by him on the sale effected on 09.12.2017 was reasonable and within the entitled and negotiated margins agreed with HP, and that the Authority had observed in the case of M/s. Flipkart, that the withdrawal 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 aft
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espondent's own statutory responsibility and obligation to pass on the benefit of reduction in the GST rate to his customers. The DGAP has also stated that it was evident from the sales data submitted by the Respondent that he had raised the per unit base price of the product post GST rate reduction w.e.f. 15.11.2017, from Rs. 705.90 (average base price for the sales made during the period 01 .10.2017 to 14.11.2017) to Rs. 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 a
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nvoice did not show the name and address of the buyer.
10. After perusal of the DGAP Report, the Authority in its meeting held on 03.10.2018 decided to hear the Applicant and the Respondent on 22.10.2018 and accordingly hearing notice was issued to all the interested parties. But the hearing was postponed to 29.10.2018 on the request of the Respondent received vide his mail dated 22.10.2018. On 29.10.2018 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
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should be deemed infructuous as the complaint under Section 171 of the CGST Act, 2017, has been filed with respect to the MRP affixed on the product by the brand owner, i.e. M/s. HP India Sales Private Limited (“HP India”), which was evident from the face of the complaint itself, wherein the above Applicant had submitted that the HP India had increased the MRP post GST rate reduction. An extract of the 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
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ufacturer is responsible for publishing MRPs on boxes and we observe that despite change in GST rates the boxes didn't reflect the revised MRPs directly or via a price sticker.”
Amount in Rs.
Particulars
Invoice dated October 4, 2017 (during sale period)
Invoice dated December 9, 2017
MRP
1,076
1,158
Sale price*
688.28
911.86
Discount*
34.38
45.59
Net sale price*
653.87
866.27
Purchase price*
696.46
798.00
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 circular
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ST Act. It has also been stated that a certificate issued by HP India, on the changes in MRPs made during the period from July 2017 to December 2017 at various points in time, was submitted vide his reply to the DGAP, and however, the DGAP in his Report had ignored these facts. Consequently, these changes in the MRPs had impacted the purchase/ procurement price of the Respondent and as a result impacted his margins as well. He has further claimed that the Applicant No. 1 must have purchased the product only when the MRP of the product was Rs. 1,076 and subsequently when it was revised to Rs. 1,158 and there did not seem to be a purchase made by the Applicant when the MRP was increased to Rs. 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 Rs. 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 furni
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enetration, customer loyalty or other similar factors, retailers like him chose to provide voluntary discounts/benefits to their customers. These benefits were discretionary and the sellers were under no statutory obligation to provide them or to withdraw them. The Respondent has also claimed that he was fully entitled to sell the product at the MRP printed on the package but had chosen to provide certain discretionary, non-statutory benefits to his customers.
17. The also submitted that in compliance with the anti-profiteering regulations, the brand owner, HP India had reduced the MRP of the product from Rs. 1,239 to Rs. 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 Rs. 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
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consider all his submissions made and record his conclusions arrived on each of his submissions which he had not done. Therefore, he has claimed that the Report of the DGAP was without proper appreciation of the facts and submissions made by him and hence, the same needs to be set aside. He has further submitted that the sale made to the above Applicant vide the first invoice dated 04.10.2017 pertained to the pre-CST imported stock. It has been further submitted 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 Rs. 1,076. Though the MRP was increased by the HP India from Rs. 1,076 to Rs. 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 t
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ffixed on the stock purchased by the above Applicant on October 4, 2017 was Rs. 1 ,076, it could be deduced that the product is pre-GST stock and therefore it was clear that the MRP of the product was not increased from Rs. 1,076 to Rs. 1,158 after rate reduction in November 2017 and the said product was never sold above the reduced MRP by the Respondent. He has also claimed that though the MRP was increased from Rs. 1,076 to Rs. 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 purc
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696 per unit. Further it has been claimed that from the complaint, it was evident that the second sale was made to the above
Applicant in the month of December on revised MRP post-rate change of Rs. 1,158, which can be clearly seen from the table given below:-
Particulars
Quantity
Opening stock as on November 1, 2017 purchased at an MRP of Rs. 696 per unit
5,499
Quantity purchased in November 2017 at Rs. 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 Rs. 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 Rs. 1,239 to Rs. 1,158. He has also produced the details of purchases as given below to substantiate his claim which is authenticated w
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yardstick for determining the profit for a retailer was the actual margin earned. He has also stated that the DGAP had ignored the purchase related information submitted to him and had not arrived at the actual profit made to conclude if there was really any profiteering on the part of the Respondent. Further it is stated that the purchase price of the said product was increased from Rs. 696.46 to Rs. 798 post August 2017 and this increase was on 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 fes
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erence earned by him was much below the entitled margin as has been computed in the table below:-
Particulars
Invoice dated October 4, 2017 (Note 1)
Invoice dated December 2017 (Note 2)
MRP
1,076
1,158
Sale price**
688.28
911.86
Discount**
34.38
45.59
Net sale price**
653.87
866.27
Purchase price**
696.46
798 00
Actual price difference*
(42.59)
68.27
Actual price difference % on sales price
(6.51
7.88%
Actual price difference % on MRP
(3.96%)
5.90%
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
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er. He has further provided the details given below and submitted that the DGAP's Report had nowhere considered this aspect of increase in the purchase price and consequent impact on the margin earned by him. A comparison of the margin as made by him vis-a-vis the entitled margin revealed that he had sold at lesser margin and well within the entitled margin agreed with HP India/ their distributors. Mere comparison of selling price without factoring the purchase price/ margin earned for computation of profiteering 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 dif
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vailable to him and withdrawal of these discounts would not amount to profiteering as the products had been sold at a price much lower than the price reduced on account of GST rate reduction. The Respondent has also argued that there was no prescribed mechanism either under the CGST Act or the CGST Rules for the procedure to be followed for determining the amount of profiteering. The methodology was determined on a case-to-case basis as might be deemed fit by the Authority and therefore in the case of the Respondent the Authority 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 Rs. 696 to Rs. 798 in the month of October 2017, and if the Respondent had continued to sell at the average base price of Rs. 705.90, as envisaged by the DGAP, he would have incurred a loss. For the 5,028 units sold by
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notice. Rule 128 of CGST Rules, 2017 provided that an application was to be filed in the manner and the form prescribed. The said Rule also provided that the Standing Committee was required to examine the accuracy and adequacy of the evidence provided in the application to determine whether there was prima facie evidence to support the claim and for a prima facie case to be established, it was pertinent that the details furnished along with the application needed to be accurate, comprehensive and adequate evidence was to be provided 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
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4.76
He has also stated that the amount profiteered per unit, as computed in the report is also incorrect. At the time of calculation of the profiteered amount, the DGAP has arrived at commensurate price (determined in column G of table given below) vis-a-vis actual sales price per unit for sales made during the period November 15, 2017 to July 31, 2018 (determined in column F of table given below). Both of these prices are cum-tax prices.
Sales during 1.10.17 to 14.11.17 (GST@28%)
Sales during 15.11.17 to 31.07.18 (GST
Commensurate price
Profiteering
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 el
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unit
214.76
182.00
Quantity sold
5,028
5,028
Total amount profiteered
10,79,813.28
9,15,096.00
*Based on sales made between November 15, 2017 to July 31, 2018
**Based on sales made between October 1, 2017 to November 14, 2018
2. Reduction in amount profiteered based revised average base price for sales made during the period July 1, 2017 to November 14, 2017
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)
705.90
710.78
Profiteering per unit
181.00
177.26
Quantity sold
5,028
5,028
Total amount profiteered
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 pr
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tion filed by the Applicant No. 1 was incomplete, inadequate and not accurate. He has also stated that a key fact that had emerged during the hearing was that the above Applicant was not the actual purchaser of the product which was admitted by the Applicant himself during the proceedings on November 26, 2018. Reiterating his earlier submissions he has stated that the present application was incomplete given the above reasons and the proceedings should be set aside on this ground alone. The submissions made above clearly indicated that the application was not filed in a proper manner and therefore the Application stood invalidated. He has also stated that the Applicant No. 1 had not provided any proof regarding 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 fi
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ded the spirit and purpose of the anti-profiteering provisions under the CGST Act, 2017.
31. The DGAP, in response to the written submissions of the Respondent, filed a rejoinder on 03.12.2018 and 06.12.2018, making the following observations:-
a. With regard to the issue raised by the respondent that the complaint filed by the Applicant was incomplete, inadequate and not accurate, the DGAP quoting Rule 128(1) of the CGST Rules, 2017, has stated that the present application was examined by the Standing Committee in its meeting held on 25.05.2018, and it was decided to forward it to the Directorate General of Anti-profiteering for investigation after satisfying that prima facie case about anti-profiteering was 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,
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y taken note of at para 13 of his Report which is reproduced below.
“the noticee were required to sell the said goods at the pre 15.11.2017 base price and charge lower GST @ 18% on such base price, to pass on the benefit of reduction in the rate of tax from 28% to 18% w.e.f. 15.11.2017. As a supplier registered under GST, it was the noticee's own statutory responsibility and obligation to pass on the benefit of reduction in the GST rate to their customers.”
d. To the issue regarding profiteering and its calculation raised by the Respondent the DGAP has stated that the calculation of profiteering had been done on the basis of increase in base price of the product post CST rate reduction w.e.f. 15.1 1.2017, from Rs. 705.90 (average base price for the sales made during the period 01.10.2017 to 14.11.2017) to Rs. 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
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duction prices have been compared and the profiteering amount has been computed accordingly, in the investigation report dated 19.09.2018.
f. With regard to amounts to be compared should have been excluding the taxes, the DGAP has stated that the price paid by the recipient included both the base price and also the tax charged on it. Therefore, any excess base price or tax collected from the recipients must be returned to the recipients and where the recipients were not identifiable, the same was required to be deposited in the Consumer Welfare Fund. With regard to the sale returns not considered, the DGAP has submitted that at time of the report the time of supply of such quantity (whether pre or post GST rate 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
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nt, was issued by the Respondent on the e-commerce platform. Since, the product was sold by the Respondent and he being registered under GST, his obligation to pass on the benefit of rate reduction still remained and holds good. Section 127 (ii) of the CGST Rules, 2017, clearly states the Authority has to identify the registered person who has not passed on the benefit to the recipient and in this case, the Respondent was clearly that registered person. Therefore, the contention that the complaint is infructuous on this ground is untenable.
(ii) Secondly, the Respondent has further stated that the complaint filed by the Applicant was incomplete, *inadequate and was not accurate and admittedly, he was not the actual 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
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roduct name are available so the question of not considering the complaint does not arise at all. Even the MRP that is written manually happens to be the correct MRP, as has been admitted by the Respondent. Therefore, the Standing Committee has rightly forwarded the same to the DGAP and the DGAP has accordingly completed its investigation and filed his Report.
35. Now coming to the issue on merits, the Respondent, referring to the invoices filed by the Applicant No. 1, has claimed that he had nothing to do with the MRP as it had been fixed by HP India, the brand owner. This argument of the Respondent is vitiated by the fact that the GST envisages that every supplier is to be registered and every registered Supplier is bound 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
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ondent has also claimed that the purchase price was increased from Rs. 696.46 to Rs. 798 post August 2017 on account of introduction of GST w.e.f. from July 2017, with the rate of tax of 28%. He has further stated that the price without tax, after considering his entitled margin of 14% was Rs. 967.97, when the MRP was Rs. 1,239. Further, it has been submitted that on reduction of GST rate of tax from 28% to 18%, the purchase price remained at Rs. 798 while price before tax with entitled margin of 15.83% increased to Rs. 981.36, when the MRP was reduced from Rs. 1,239 to Rs. 1,158. Thus, overall his entitled margin percentage on selling price had increased from 17.56% to 18.68%. This statistics itself clearly shows that when the MRP reduced from Rs. 1 , 239 to Rs. 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 Rs. 13.39 per unit and on this increased price GST of 18% has also been
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based on this he had arrived at total profiteered amount of Rs. 7,82,425.60 taking into account the sale returns of 614 units. The Respondent has not disputed the base price arrived at by the DGAP for the period 15.11.2017 to 31.07.2018 which is Rs. 887.90. His only objection is that the comparable period should also be from 01.07.2017 to 14.1 1.2017 since many of the old MRP products were also being sold during this period. Perusal of Annexure-13 of the Report of the DGAP shows that he has rightly calculated the base price of the product based upon the average sale price charged by the Respondent between the period from 01 .10.2017 to 14.1 1.2017 and 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 R
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Black and Tri-Color
705.90
11471
887.90
5028
1047.72
838.96
214.76
10,79,813.28
39. Accordingly the Respondent is directed to reduce the price of the above product as per the provisions of Rule 133 (3) (a) of the CGST Rules, 2017 by making commensurate reduction in the prices, keeping in view the reduction in the rate of tax. The Respondent is also directed to deposit the profiteered amount along with interest at 18% when the above amount was collected by him from his recipients till the date of deposit. The Applicant No. 1 has admitted that the product was not purchased by him hence the question of refund does not arise. Hence the Respondent is directed to deposit the entire amount of Rs. 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
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Manipur
1
214.76
107.38
19
Mizoram
2
214.76
214.76
20
Nagaland
1
214 76
107.38
21
New Delhi
561
214.76
60240.18
22
Odisha
34
214.76
3650.92
23
Puducherry
14
214.76
1503.32
24
Punjab
112
214.76
12026.56
25
Rajasthan
88
214.76
9449.44
26
Tamil Nadu
479
214.76
51435.02
27
Telangana
379
214.76
40697.02
28
Tripura
3
214.76
322.14
29
Uttar Pradesh
313
214.76
33609.94
30
Uttarakhand
16
214.76
1718.08
31
West Bengal
263
214.76
28240.94
Grand Total
5,028
5,39,906.64
40. From the above discussions it has been established that the Respondent has profiteered by increasing his base price. Hence he is liable for penalty under Section 122(1)(i) of the CGST Act, 2017, for issuing incorrect invoices. In the interest of natural justice before imposition of penalty a notice for hearing need to be issued.
41. A copy of this order be sent to the Applicants and the Respondent and to the respective Commissioners of CGST/SGST fr
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