TMI Blog2021 (9) TMI 1064X X X X Extracts X X X X X X X X Extracts X X X X ..... usiness arrangement between AAI and SPV is a transfer of going concern or otherwise? - HELD THAT:- Transfer of a going concern means transfer of a running business which is capable of being carried on by the transferee as an independent business in continuity without any hindrance for a foreseeable period. Such transfer of business will comprise transfer of assets for running the business. Such transfer as going concern may involve transfer of employees as requisite to carry on the business without interruption. In effect, it implies that the business will continue in the new hands with regularity and a nature of permanency - subject business arrangement between AAI and SPV merits to be covered under transfer of going concern. Whether the transfer of business by AAI to SPV be treated as Supply under Section 7 CGST? - HELD THAT:- From the construction of the wordings in sections 18(3); 22(3) and 85(1); Schedule II(4) of CGST Act and the Rule 41(1) CGST Rule, it is found that transfer of Business is more of an event in pursuance to a business arrangement - subject business arrangement is Transfer of business of an independent part with respect to SVP International Airport b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... per law. - GUJ/GAAR/R/46/2021 - - - Dated:- 27-8-2021 - SANJAY SAXENA AND ARUN RICHARD MEMBER Present for the applicant : Shri Hem M Chhajed, CA Brief Facts: 1. M/s. Airport Authority of India (hereinafter referred to as AAI, for the sake of brevity) is an authority created under the Airport Authority of India Act, 1994 (hereinafter referred to as the AAI Act). The AAI Act was enacted to provide for the constitution of the AAI for the better administration and cohesive management of the airports. AAI has been created for the purpose of establishing or assisting in the establishment of airport and for the matters connected thereto. 2. As per Chapter III, Section 12(1), (2) of AAI Act, the functions of the AAI are : (i) To manage the airports, the civil enclaves and the aeronautical communication stations efficiently; (ii) To provide air traffic service and air transport service at any airport. 3. Further, AAI may undertake various activities specified in Section 12(3) of AAI Act, as required from time to time to achieve the above object such as: (i) Plan, develop, construct and maintain runways, taxiways, aprons, terminals and ancillary build ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unctions under section 12 as the AAI may deem fit. 5. In the pursuance to Section 12A of AAI Act, the AAI has invited bids for undertaking the operation, management and development of certain airports of the AAI on a public private partnership basis to bring efficiency in service delivery, expertise, enterprise and professionalism and to harness necessary investment. 6. Single stage two envelop system through Central Public Procurement Portal was followed for selection of successful bidder for the Operation, Management and Development of Sardar Vallabhai Patel Airport for a lease period of 50 years ( Project ). Request for proposal (RFP) documents for the Airport was issued on 14-12-18. The Project would be implemented in accordance with the terms and conditions stated in the RFP and Concession Agreement dated 14-2-20 entered into between the Authority and the Concessionaire ( the selected bidder). 7. In 2019, Airports Authority of India conducted PPP (Public Private Partnership) bidding process in which M/s. Adani Enterprises Limited (the Concessionaire ), an Ahmedabad-based business conglomerate had won the bid of the airport quoting highest bid among all. 8. The Con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t. AAI will cease to operate, manage and develop the airport as per this agreement from a prescribed date. 12. lt is important here to refer to the definition of the terms, Airport, Project and 'Project Assets' as defined in the agreement. The relevant definitions are as follows: Airport means Sardar Vallabhbhai Patel International Airport located at the Site, and includes civil, mechanical and electrical works, the Terminal Building, Cargo Facilities, Runway and all Project Assets necessary for and associated with operation and expansion of the Airport. Project means the operations, management and development of the Airport in accordance with the provisions of this Agreement, and includes all works, services and equipment relating to or in respect of the Scope of the project. Project Assets means all physical and other assets relating to or forming part of the Site including: a) rights over the Site in the form of lease, Right of way or otherwise; b) the Aeronautical Assets and the Non-Aeronautical/ Assets; c) tangible assets such as civil works and equipment including foundations, drainage works, electrical systems, communication syste ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... maintenance and management of the Airport; c) development, operation and maintenance of City Side; d) Performance and fulfilment of other incidental matters. Article 3 Grant of Concession The concession under this agreement includes the exclusive right, lease and authority to operate, manage and develop the Airport for a period of 50 (fifty) years commencing from the COD which will oblige and entitle to the SPV for following: a) the Right of Way, access and lease to the Site for the purpose of and to the extent conferred by the provisions of this Agreement; b) finance the development and expansion of the Airport; c) Operate, maintain and manage the Airport and regulate the use thereof by third parties; d) demand, collect and appropriate Fee from Users liable for payment of Fee for using the Airport or any part thereof and refuse entry of any such User if the Fee due is not paid; e) perform and fulfil all of the SPV's obligations under and in accordance with this Agreement; f) save as otherwise expressly provided in this Agreement, bear and pay all costs, expenses, Taxes an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... I which include assistance to the SPV to perform functions in accordance with the present agreement. Also, SPV shall be liable to pay the AAI such amounts as on COD in respect of the contract relating to work in progress. Article 7 Representation and warranties Representation by the parties to contract that they are capable to enter into this contract and perform the functions under the contract. Article 9 Performance security SPV undertakes to perform certain functions under this agreement and to ensure these performances, SPV must provide performance security of ₹ 130 Crores. Further, there are provisions of appropriation of the said security in case of non-fulfilment of obligations prescribed and release of performance security on fulfilment of underlying conditions under the contract. Article 10 Right of way The AAI undertakes to grant of way to the SPV for carrying out survey, investigation etc. It further undertakes to grant lease of the land on payment of monthly concession fees. Article 12 Development and expansion o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted Gol agencies can undertake certain prescribed services like security services, customs control etc. Article 22 Traffic regulation and census The SPV shall regulate vehicular traffic, evolve system thereof. The SPV shall also collect the data relating to airside and landside passengers. Further, it shall install, operate and maintain computer system for efficient transparent management of traffic. Article 23 Key performance indicators The SPV shall operate the airport such that it achieves or exceeds the specified key performance indicators and service quality indicators. However, this article does not apply to city side development. Article 24 lndependent Engineer Appointment of independent engineer for performance of duties and functions as set forth in schedule L of the agreement. These duties and functions include: review of design and drawings, review, inspection and monitoring of Construction work; reviewing and witnessing the Tests on completion of construction review, inspection and monitoring of O M; deter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he extent specified. Further, the SPV shall pay the AAl, the amount equal to the estimated depreciated investment made by the AAI in the aeronautical assets as well as in non-aeronautical assets. Article 30 Insurance The SPV shall obtain proper insurance for various contingencies and comply with the conditions prescribed for insurance policies. Article 34 Suspension of SPV's rights Upon occurrence of the SPV's default, the AAI shall be entitled to suspend rights of the SPV under this agreement and the AAI can act on behalf of the SPV. Article 35 Termination Various contingencies leading to termination for the SPV's default or for the AAI'S default are agreed. Termination payment in case of termination on account of default of either parties or termination on account of expiry of concession period is also provided. Article 43 Redressal of public grievances The SPV shall maintain public relation office at the airport where complaint register shall also be kept. The SPV shall inspect the complai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l authority in which they are engaged as public authorities, as may be notified by the Government on the recommendations of the Council, shall be treated neither as a supply of goods nor a supply of services. (3) Subject to the provisions of 40[sub-sections (1), (1A) and (2)], the Government may, on the recommendations of the Council, specify, by notification, the transactions that are to be treated as- (a) a supply of goods and not as a supply of services; or (b) a supply of services and not as a supply of goods. (iii) On reading the above definition it is clear that the transaction will constitute supply only when the following conditions are satisfied: a. Supply should be of goods or services b. Supply should be made for a consideration c. Supply should be made in the course of furtherance of business GST is leviable on supply of goods as well as supply of services. Hence, for levy to sustain, it is important to analyse whether underlying transaction in the present case amounts to supply of goods or services. In terms of Sec. 2(52) of CGST Act, goods means every kind of movable property other than money and securities but includes actionable cl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... following conditions: (i) Service by way of transfer; (ii) The transfer should be of the going concern; (iii) Such transfer must be as a whole or an independent part thereof It becomes imperative to understand the meaning of word 'transfer' in the above exemption entry. In general connotation transfer can be permanent as well as temporary. Union of India vs Dr. Maqsood Ahmed [AIR 1963 Bom110, 114], wherein, the Court has held that, the word transfer is a larger word and the word sale is a specific word. A transfer may be by means of a lease, mortgage or sale or in any other mode. (v) It would be worthwhile to note that whilst the definition of supply includes sale but the exemption notification does not refer to sale of going concern to be exempted. It uses the word transfer . Given that there is no definition of transfer , two views are possible. The first view is that it could mean an outright sale. The second view could be that it may not necessarily mean outright sale because if the intention of the legislature was to exempt sale of going concern, it could have used the term sale. However, it has used the word transfer of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... its of property which results in terminating rights and other relations in one entity and creating them in another. While construing the word transfer due regard must be had to the thing to be transferred. This ruling was confirmed by Supreme Court [Refer State of Andhra Pradesh Anr. vs M/s. Rashtriya Ispat Nigam Ltd. (Appeal (civil) 31 of 1991)] b. Bharat Sanchar Nigam Ltd. vs UOI [2006] 3 STT 245(SC) While dealing as to what constitute a transaction for the transfer of the right to use the goods the Supreme Court laid down certain attributes which must be present in a transaction. One of the attributes was that for the period during which the transferee has such legal right, it has to be the exclusion to the transferor - this is the necessary concomitant of the plain language of the statute - viz. a transfer of the right to use and not merely a licence to use the goods. c. Indus Towers Ltd. vs Deputy Commissioner of Commercial Taxes, Enforcement 1, Bangalore and Others [[2012] 56 VST 369 (Kar)] In the context of transfer of right to use goods, the High Court held that what is important is that the legal right transferred to use the goods in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... parlance denotes the stand alone or capable of being functional individually. The concept of business is changing, and new age business undertaking may contain various different businesses and a single business out of the entire business undertaking may contain different units. In such scenario, even transfer of a unit can be said to be transfer of independent part of business In the present case, we understand that the Airport is capable of operating as an independent unit. The operation of the airport can generate revenue. Hence, it can be said that the airport is an independent part of a going concern of the applicant. (xiii) The applicant relies on following pronouncements: The Karnatka Authority for Advance Ruling in case of M/s Rajashri Foods Pvt. Ltd. (Karnataka AAR), held that, the activity of transfer of a going concern constitutes a supply of service. The ruling further held that the transaction of transfer of one of the units of the Applicant as a going concern is covered under Sr. No.2 of the Notification No.12/2017 Central Tax (Rate) dated June 28, subject to the condition that the unit is a going concern The authority further analysed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... airport from first person to second and subsequently from second person to first amounts to transfer of business by one person to another as a going concern. b. In case of Robinson Family Limited vs. the Commissioners for Her Majesty's Revenue and Customs (20121 UKFTT 360 GC) , Hon'ble United Kingdom First Tier Tribunal has held that transfer of property by way of lease for the letting business amounts to transfer of a going concern. (xvi) Therefore the applicant submits that a view can be taken that the transaction amounts to services by way of transfer of a going concern, as a whole or an independent part thereof which is covered in the entry 2 of the exemption Notification No. 12l2017-Central Tax (Rate) dated 28 June 2017. (xvii) As per the concessionaire agreement, apart from a lump sum consideration, monthly concession charges would also be paid by the Company to AAI. Thus it can regarded that the entire arrangement as one and covered within the meaning of transfer of going concern and thus exempted. (xviii) Monthly/ annual concession fees paid by the concessionaire to the Applicant consideration for granting lease right of land, building and the immov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... government to levy any tax on land which is produced hereunder: 49. Taxes on Land and Buildings (xxiv) Applicant is of the view that a long term lease for a period exceeding 30 years tantamount to Sale of the immovable property since the lessor is deprived of the right to use, enjoy and possess the property once the said lease has been granted. (xxv) Further attention is also drawn to Article 30 of the Gujarat Stamp Duty Act wherein the aforesaid transaction is treated as conveyance. (xxvi) The applicant draws attention to the decision of the Hon ble Bombay High Court in the case of Navi Mumbai Builder s Association v. Union of India, 53 GSTR 374, which is held as follows: On a plain reading of the GST Act, the argument of the assessee is not agreeable. The assessee also relies upon Schedule II, which is referable to section 7. These are the activities to be treated as supply of goods or services. The substantive provision section 7 in clearest terms says that the activities specified in Schedule I made or agreed to be made without a consideration and the activities to be treated as supply of goods or supply of services referred to in Schedule II would be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emium would not attract or invite the liability to pay tax in terms of the GST Act. (xxvii) The applicant submits that if the monthly/ annual fees are considered to be consideration for transfer of business over and above the initial/ upfront payments then the exemption shall be available and thus Navi Mumbai Builder s Association v. Union of India is distinguishable. (xxviii) The applicant submits that it receives reimbursement of property tax, water tax, electricity etc. payable from the concessionaire. The applicant submits that the said reimbursements are in nature of pure agents and thus cannot be treated as supply under section 7 of the CGST Act. (xxix) The applicant also raises invoice for emoluments of various employees of AAI engaged by the concessionaire i.e. Adani Group . The applicant submits that the said invoice is raised to covered the emoluments of the Government employees transferred under the agreement. (xxx) The applicant submits that the said employees were transferred along with the business. Hence if the transfer of business is treated as transfer as going concern as just exempted vide Entry No. 2of the exemption notification No 12/2017 Ce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the purpose of the operations of Ahmedabad airport. (v) The applicant has merely passed over its liability arisen out of the employment contracts of the select employees to the concessionaire. And thus this cannot be considered as any damages levied upon the concessionaire. (vi) The Ld. Bench had inquired whether the contracts have been novated and whether the concessionaire has taken insurance. As per the communication received from the concessionaire all the contracts have been novated, aero dome license has been issued and requisite insurance has been taken. (vii) The Ld. Bench had inquired whether the concessionaire has paid any fee/consideration during the inception period. As per concession agreement, the inception period refers to the period commencing from the date execution of concession agreement and expiring upon occurrence of Commercial Operation Date. Applicant submits that during the inception period the concessionaire is not required to pay any fee to applicant. (viii) The Ld. Bench has inquired that for how many years the applicant has obtained the airport land on lease form government. Applicant submits that the land for the airport has been acquired ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the AAI on the M/s. Adani Ahmedabad International Airport Limited? 8. Whether GST is leviable on the invoice raised by AAI for reimbursement of the salary/ staff cost on M/s. Adani Ahmedabad International Airport Limited? If yes at what rate? 9. Whether GST is applicable on the reimbursement claimed of Municipal tax, Property Tax and Water Charges by the AAI from M/s. Adani Ahmedabad International Airport Limited? If yes at what rate? 10.Whether GST is applicable on transfer of spares and consumables for consideration by the AAI to M/s. Adani Ahmedabad International Airport Limited? If yes at what rate? Personal Hearing 16. Personal Hearing was granted on 27-7-2021. However, AAI requested for adjournment. 17. Further, another Personal Hearing was granted on 12-8-21 Shri Hem M Chhajed, CA appeared for hearing ( Video Conferencing) on 12-8-21 and reiterated the contents of the application. To specific enquiry with respect to Question 10, he was asked to submit the list of consumables and spares on which AAI seeks to know the GST rate. Shri Chajed requested to withdraw this Question 10 with respect to Tax rate, as he was not in a position to submit the list ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of assets for running the business. Such transfer as going concern may involve transfer of employees as requisite to carry on the business without interruption. In effect, it implies that the business will continue in the new hands with regularity and a nature of permanency. 23. We detail our findings on the issue if subject Contract entered between AAI and SPV merits transfer of Going Concern or otherwise, as follows: i. Foreseeable Future We find that the subject Business Arrangement has been set in place for 50 years, which is for a forseeable future spanning 5 decades. We find that subject Contract is for transfer of the development, maintenance and management of SVP International Airport, Ahmedabad from AAI to SPV. In pursuance to AAI Act, The AAI has constructed the airport at Ahmedabad and has been operating it under and in accordance with the AAI Act. SPV has taken insurance, novated all the existing agreements as mentioned in Schedule V, so as to maintain effective running of operations of the airport. We find that SPV has entered into Memorandum of Understanding with the Government of India as per Schedule R to the said Contract. On plain reading of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arjiwan-1987-65-STC-450 (Bom). iii. Legal backing for Transfer of functions to AAI to SPV We refer to the provisions to Section 12A of AAI Act, wherein as per Section 12(A) subsections (1) and (4), AAI, in the the public interest or in the interest of better management of airport may lease premises of an airport (including buildings and structures thereon and appertaining thereto) to carry out some of its functions under Section 12 as AAI may deem fit, and SPV who had been assigned this function of the AAI shall have all the powers of AAI necessary for the performance of such functions. We find that AAI has transferred to SPV the exclusive right and authority to operate, manage and develop the Airport for a period of 50 years commencing from the Commercial Operation Date covering the following functions, as follows: (a) design, development, financing, construction, up-gradation and expansion of the Airport in a phased manner (b) operations, maintenance and management of the Airport in accordance with the provisions of the Agreement, Applicable laws and Applicable Permits; (c) development, operation and maintenance of City side (d) performance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ransfer of part business of AAI to SPV. d. We note Article 2 of the subject contract wherein the scope of the Project is detailed, which includes the operation, management and development of the airport. We further note that airport also includes all project assets necessary for and associated with the operation and expansion of the airport. There project assets are physical and other assets relating to or forming part of the site including the rights over the site in the form of lease, right of way or otherwise; the aeronautical assets and non aeronautical assets; tangible assets such as civil works and equipment including foundations, drainage works, electrical systems, communication systems and administrative office; project facilities situated on the site; buildings and immovable fixtures or structures forming part of city side development; all rights of the concessionaire under the project agreements; financial assets such as receivables, security deposits , all negotiable instruments etc; insurance proceeds; applicable permits and authorisations relating to or in respect of the airport. We find that the Contract is self-contained to ensure that Airport business continu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... means every kind of movable property other than money and securities but includes actionable claim, growing crops, grass and things attached to or forming part of the land which are agreed to be severed before supply or under a contract of supply. 24.1 With reference to said definition, we find that business is not Goods for it is not a movable property and thereby Transfer of Business cannot be supply of goods. 24.2 We now refer to the definition of Service. Section 2(102) CGST Act defines Service as follows: services means anything other than goods, money and securities but includes activities relating to the use of money or its conversion by cash or by any other mode, from one form, currency or denomination, to another form, currency or denomination for which a separate consideration is charged. What we have before us is whether Business may be covered under the umbrella of the definition of Service, as per Section 2(102 ) CGST Act. To ascertain the same, we refer to the definition of business. We reproduce the definition of Business as per Section 2(17) CGST Act, as follows: 2(17) business includes (a) any trade, commerce, manufacture, profession, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Business includes supply of goods and Business in connection with commencement or closure of business 24.5 Further, on careful reading of the provisions of CGST Act and Rules, we find the phrase Transfer of Business has been mentioned in i. CGST Act at the following sections- Section 18(3) ; section 22(3); section 85 ii. CGST Rules Rules 41. iii. Schedule II(4)(c) to CGST Act. Section 18(3)CGST Act reads of follows: 18(3) Where there is a change in the constitution of a registered person on account of sale, merger, demerger, amalgamation, lease or transfer of the business with the specific provisions for transfer of liabilities, the said registered person shall be allowed to transfer the input tax credit which remains unutilised in his electronic credit ledger to such sold, merged, demerged, amalgamated, leased or transferred business in such manner as may be prescribed. Section 22(3) CGST Act reads as follows: (3) Where a business carried on by a taxable person registered under this Act is transferred , whether on account of succession or otherwise , to another person as a going concern , the transferee or th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 11(1) CGST Act reads as follows: Section 11. (1): Power to grant exemption from Tax) Where the Government is satisfied that it is necessary in the public interest so to do, it may, on the recommendations of the Council, by notification, exempt generally, either absolutely or subject to such conditions as may be specified therein, goods or services or both of any specified description from the whole or any part of the tax leviable thereon with effect from such date as may be specified in such notification. 24.8 We note that in exercise of powers conferred under Section 11(1) CGST Act, the Central Government has issued Notification 12/2017CT(R) dated 28-6-2017, wherein at serial no. 2 of said Notification, reads the description of service as Services by way of transfer of a going concern, as a whole or an independent part thereof . The plain meaning of the words services by way of transfer of a going concern, is Transfer of a going concern service . This is the interpretation of these wordings at the cited sr no. 2 of the said Notification12/2017-CT(R). 24.9 Now taking our cue from the said Sr no. 2 of Notification 12/2017 which has been issued in exercise of po ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by AAI to SPV is treated as supply as going concern and covered in clause 4 of schedule II of CGST Act? 26. We find from the aforementioned discussions and findings that the subject transfer of business by AAI to SPV is treated as supply of going concern. We refer to Schedule II (4) CGST Act, reproduced as follows: 4. Transfer of business assets (a) where goods forming part of the assets of a business are transferred or disposed of by or under the directions of the person carrying on the business so as no longer to form part of those assets, whether or not for a consideration, such transfer or disposal is a supply of goods by the person; (b) where, by or under the direction of a person carrying on a business, goods held or used for the purposes of the business are put to any private use or are used, or made available to any person for use, for any purpose other than a purpose of the business, whether or not for a consideration, the usage or making available of such goods is a supply of services; (c) where any person ceases to be a taxable person, any goods forming part of the assets of any business carried on by him shall be deemed to be supplied by him ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d) in the performance of its obligations under the Contract. iv. SPV shall provide or cause to be provided Aeronautical and Non aeronautical services at the Airport in accordance with the subject contract, applicable laws and applicable permits. v. SPV shall procure electricity, telecommunication services, water and other utilities, as may be necessary for the operation of the Airport, from respective local utilities upon payment of charges in accordance with applicable laws. vi. As per Article 5.14, the SPV is set up for the sole purpose of exercising the rights and observing and performing its obligations and liabilities under this Agreement, i.e., the operation, management and development of the Airport. SPV shall not have any shareholding interest or otherwise in any entity, or any other form of arrangement with any person, which may allow it to undertake or perform any other business activity. vii. The Airport shall be known, promoted, displayed, advertised and branded by the same name of SVP International Airport only at all times and SPV shall ensure that any advertisement, display or otherwise at or in relation to the Airport shall contain the logo of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Transfer of Going concern service envisaged in the substance of the Contract. Concession Fees: i. We have discussed in the aforementioned paragraphs that consideration may be as per the terms and conditions of the Contract and there is no restriction on consideration being upfront/ one time/ in instalments/ as per agreed terms of the Contract. ii. We find that Concession fees are paid by SPV to AAI during the concession period, calculated on a formula based on passenger footfall. We make it clear that Concession fees payable by SPV to AAI are not to be confused with the user fees payable by the users to SPV. iii. On specific enquiry to Shri Chajed, during the personal hearing, he submitted that AAI had not received any Concession fees during the Inception period and that all the concession fees were received by it after the Commencement of Operations (COD). 28. We note that AAI has sought Ruling on its Question No. 10 whether GST is applicable on transfer of spares and consumables for consideration by AAI to SPV? If yes, at what rate? 28.1 During the Personal Hearing, Shri Chajed was required to submit the details of the goods and related docume ..... X X X X Extracts X X X X X X X X Extracts X X X X
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