TMI Blog2022 (10) TMI 461X X X X Extracts X X X X X X X X Extracts X X X X ..... 2% and during the post-GST period (July-2017 to December-2018), it was 6.66% for the project Godrej 24 . This confirms that, post-GST, the Respondent has been benefited from additional ITC to the tune of 3.64% [6.66% (-) 3.02%] of his turnover for the said project and the same was required to be passed on to the customers/flat buyers/recipients. The DGAP has calculated the amount of ITC benefit to be passed on to the customers/flat buyers/recipients as Rs. 6,89,62,698/- for the project Godrej 24 , the details of which are mentioned in Table- B above. Further as per Table-C of DGAP, the profiteering amount to be passed on to the Applicant No. 1 is nil as no post-GST billing during the investigation period was made to Applicant No. 1. The Authority finds no reason to differ from the above detailed computation of profiteered amount by the DGAP or the methodology adopted by it. The Authority determines that the Respondent has profiteered an amount of Rs. 6,89,62,698/-(Rupees Six Crore Eighty-nine Lacs Sixty-two Thousand Six Hundred Ninety-eight only) during the period under present investigation i.e. 1.07.2017 to 31.12.2018, in the present Project - the Authority under Rule 133 (3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had alleged profiteering by the Respondent in respect of purchase of Flat in the Godrej 24 project of the Respondent. II. A Notice under Rule 129 of the CGST Rules, 2017 was issued by the DGAP on 14.01.2019 calling upon the Respondent to reply as to whether he admitted that the benefit of ITC had not been passed on to the Applicant No. 1 by way of commensurate reduction in price and if so, to sun moto determine the quantum thereof and indicate the same in his reply to the Notice as well as furnish all supporting documents. III. The period of investigation was from 01.07.2017 to 31.12.2018. IV. As per the directions of the Authority issued vide Internal Order No. 08/2020 dated 03.01.2020 , the DGAP initiated a re-investigation of the case. The case had been re-investigated on the basis of new data submitted by the Respondent. The main issues/ Paras raised by the Authority vide Internal Order No. 08/2020 and ensuing DGAP findings were as follows:- a) Para 71 It is further revealed from the record that the Respondent had claimed that the carpet area relevant to turnover considered by the DGAP was incorrect. He had also supplied both the figures which had bee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ara 74: It is further apparent from the perusal of para 18 of the report dated 26.06.2019 furnished by the DGAP that the Respondent had booked 892 units. Whereas the Respondent had vehemently claimed in his submissions that the total number of the units in his Godrej 24 project was 816. Since there is a vast difference in the number of units claimed by both the parties the same is required to be reconciled . DGAP's Reply on Para 74 - The contention of the Respondent that the total number of units in his Godrej 24 Project was 816 in place of 892 units had also been examined. The submission of the Respondent had been verified with the details available on the Maharashtra RERA website wherein tower-wise units had been mentioned and it is observed that there were 815 units. On being pointed out it, had been clarified by the Respondent vide his email dated 24.01.2021 that the number of units in the project was 816, and the number of units registered in RERA was 815 units since one unit is being kept as a guest house to be managed by the society. Accordingly, the element of profiteering had been recalculated as detailed in the following para(s) considering the 816 uni ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e) in respect of the flats for the project Godrej 24 sold by them. Moreover, since the Respondent was paying VAT @1% under Maharashtra VAT Composition Scheme, he was not eligible to avail ITC of VAT paid on the inputs. Further, post-GST, the Respondent could avail ITC of GST paid on all the inputs and input services. From the data submitted by the Respondent vide letter /email dated 21.09.2020 and 24.01.2021, the ratio of ITC to turnover, during the pre-GST (April 2016 to June 2017) and post-GST (July 2017 to December 2018) periods, was furnished in Table-A below. Table A (Amounts in Rs.) Sr.No. Particulars 'Total (Pre-GST) April, 2016 to June, 2017 Taxable Turnover (July, 2017 to December, 2018) 1. CENVAT Credit of Service Tax Paid on Input Services (A) 1,33,30,931 - 2. Credit of VAT paid on Purchase of Inputs(B) - - 3. Input tax credit of GST Availed (C) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Base Price raised during July, 2017 to December, 2018 (Rs.) E 169,15,88,954 9. GST raised over Base Price (Rs.) F=E*B 20,29,90,674 10. Total Demand raised G=E+F 189,45,79,628 11. Recalibrated Base Price H=E*(1-D) or 96.36% of E 163,00,15,116 12. GST @ 12% I=H*B 1956,01,814 13. Commensurate demand price J=H+I 182,56,16,930 14. Excess Collection of Demand or Profiteering Amount K=G-J 6,89,62,698 From Table- B above, it is clear that the additional ITC of 3.64 % of the turnover should have resulted in a commensurate reduction in the base price as well as cum-tax price. Therefore, in terms of Section 171 of the CGST Act, 2017, the benefit of such additional ITC was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as per Annex-8 Benefit already passed on by the Respondent (Annex-I) Remarks A B C D E F G I 1. Applicant 1 931 - - - No demand Raised Post GST 2. Home buyers with ZERO demand raised in Post GST period (No ITC benefit passed) 15 17,025 - - - No demand Raised Post GST 3. Home buyers with ZERO demand raised in Post GST period (ITC benefit passed) 2 2,622 - - 2,11,189 No demand Raised Post GST 4. Home buyers with demand raised in Post GST period (ITC benefit passed) 645 7,36,607 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Category of home buyers No of home buyers Actual ITC benefit passed on by the Respondent to mentioned home buyers Proportionate eligible ITC benefits which had to be passed on to the home buyers Pending eligible ITC benefit to be given (Proportionate ITC to be given - Actual ITC benefit given) A B C Home buyers with excess ITC 28 (54,29,635) 32,89,455 -21,40,180 Home-buyers with deficit ITC 31 (37,35,333) 37,71,438 36,105 Total 59 91,64,968 70,60,893 36,105 V. The excess amount of ITC benefit Rs. 21,40,170/- given to the 28 home buyers (categorized as home-buyers with excess ITC) and the difference amount of Rs. 36,105/-which had to be given to the 31 home buyers (categorized as home ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... passed on the agreement value. 2.25% (approx.) has been passed on through reduction in the price which is reflected either in the cost sheet or the invoices are billed to customers based on revised agreement value Remaining 1.63% (approx.) has been passed on the amount of billing done in GST regime through credit note or adjustment in the tax invoice itself C. Sub-Total (A+B) 669 8,06,63,836 D. Customers who booked units after 30.06.2018 till 31.12.2018 68 In respect of units booked after 1 year of introduction of GST, the price offered to customers is after considering the benefit of ITC as per Section 171 of the CGST Act and other market conditions. E. Unsold Units as on 31.12.2018 79 F. Total Units (C+D+E) 816 A.3 The Applicant belongs to Category A i.e. it has booked the unit in earlier regime. It is a fact on record that the Res ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e to the customer during the process of verification. Also, DGAP has neither asked Respondent nor followed up with the customers who have either not submitted replies or submitted incomplete replies. C. The Anti-profiteering proceedings are time-barred. C.1 In terms of rule 133(1) of the CGST Rules, the Authority is required to determine whether the registered person has passed on the benefit of the reduction in the rate of tax on the supply of goods or services or the benefit of input tax credit to the recipient by way of commensurate reduction in prices, within six months from the date of the receipt of report from the DGAP. Further, the Authority has powers to seek clarifications from DGAP u/r 133(2A) and also refer the matter to DGAP to cause further investigation or inquiry in accordance with the provisions of the Act and the rules, if the Authority is of the said opinion that further investigation or inquiry is required. C.2 The fresh time limit available to a new investigation is not available to a further investigation u/r 133 (4), and that the further investigation u/r 133 (4) needs to be completed and final order of the NAA needs to be passed within the overall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... benefit of input tax credit has been accrued which shall be computed and passed on to the customers. D.4 In other words, the consideration of bookings made in GST regime were determined based on various factors including benefit of input tax credit, if any, u/s 171 of the CGST Act as well as applicable GST rates under GST regime and the same shall be outside the scope of calculation to be done by DGAP. D.5 The Respondent placed reliance on the Order of National Anti-Profiteering Authority in the case of Ms. Hermeet Kaur Bakshi Vs. Conscient Infrastructure Pvt. Ltd. Further the Respondent also placed reliance on a case before the Hon'ble Delhi High Court in DRA Aadithya Projects Pvt. Ltd. vs UOI Ors. (W.P. (C) 2970/2021). D.6 Accordingly, an amount of INR 3,15,57,382/- needs to be excluded from the total profiteering determined in the DGAP report. The calculation of INR 3,15,57,382/- is as follows: A Turnover for Units booked in GST regime i.e. between 01.07.2017 to 31.12.2018 Rs.77,40,72,371/- B Anti-profiteering % computed by Ld. DG 3.64% ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d during July 2017 to December2018 Rs. 1,6 9,15,88,954/- B Value of Land (1/3rd) Rs. 56,38,62,984/- C Anti-profiteering % computed by Ld. DG 3.64% D Additional GST also alleged to be collected from customers 12% E Amount of profiteering computed by Ld. DG attributable to land value [B*C*(1+D)] Rs. 2 29,87,566/- F. Comparison of ratio of input tax credit to turnover for the pre-GST period and GST period is not the correct mechanism for calculation of profiteering amount. F.1 The DGAP has arrived at the figures of alleged profiteering on the basis of the difference between the ratio of input tax credit to turnover under the pre- GST and GST period. It is submitted that using this formula for calculating the benefit of additional input tax credit accrued to the Respondent will never yield the correct quantum of profiteeri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te of tax. F.4 In light of the above submissions, the Respondent submitted that the approach of comparison of ITC to turnover ratio for pre-GST and post GST period for a limited period instead of project duration is not a correct approach and profiteering computed on basis of same is liable to be rejected on this count itself. G. Benefit passed by the Respondent shall be added in turnover computation G.1 Respondent contended that while computing the profiteering percentage and amount, DGAP has considered the figure of turnover which is net of benefit passed on to customers. G.2 However, the profiteering percentage can be correctly computed only when the benefit amount passed on by the Respondent is added to the turnover for the GST period. The gross turnover shall be considered for computing the profiteering percentage and profiteering amount. H. The alleged profiteering amount has been incorrectly inflated in the report by adding GST and the same is not sustainable. H.1 The Respondent submitted that for computing the profiteered amount, the difference shall be calculated between the base price during the relevant period vis- -vis the recalibrated base pric ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to be necessarily borne by the Applicant, (GST being an indirect tax). It is submitted that being an indirect tax, the burden of the same is to be borne by the recipient, and thus, an increase in the total cost cannot be a ground to say the Respondent has indulged in profiteering. This argument is further substantiated by the fact that the Respondent had reduced its base price and the increase in the total cost was because of the increase in the rate of output tax and other reasons. I.3 In view of the foregoing, it is submitted that the Standing Committee erred in referring the matter to the DGAP in absence of any accurate or adequate evidence. Therefore, the entire proceedings based on such an erroneous prima facie conclusion is bad in law and is liable to be set aside. J. The report cannot go beyond the application submitted by the Applicant vide letter dated 12.10.2018. J.1 It is submitted that the report of the DGAP has gone beyond the application submitted by the Applicant and is liable to be rejected on this ground alone. J.2 It is submitted that an anti-profiteering investigation can be initiated only on receipt of a written application from an interested party ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aside. K.1 It is submitted that the CGST Act read with the CGST Rules does not provide the procedure and mechanism of determination and calculation of profiteering. In absence of the same, the calculation and methodology used in the report are arbitrary and violate principles of natural justice. K.2 Rule 126 of the CGST Rules contains provisions regarding the power to determine the methodology and procedure. As per Rule 126, the Authority has the power to determine the methodology and procedure for a determination as to whether the reduction in rate of tax on the supply of goods or services or the benefit of input tax credit has been passed on by the registered person to the recipient by way of commensurate reduction in prices. It is pertinent to note that as on date, CGST Rules have not prescribed any procedure/ methodology/ formula/ modalities for determining/calculating 'profiteering'. K.3 The National Anti-Profiteering Authority under the Goods and Service Tax Methodology and Procedures, 2018 ( Procedure and Methodology') issued on 19.07.2018 by the Authority only provides the procedure pertaining to investigation and hearing. However, no method/formula h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of natural justice. M.2 The Respondent submitted that the present proceedings have been issued in violation of principles of natural justice as show cause notice has not been issued to the Respondent proposing the action to be taken by the NAA. Moreover, the investigation was initiated basis the application filed by the Applicant and the Respondent was not given any chance to clarify or explain its communication. N. OTHER GROUNDS N.1 It is thus submitted that the entire proceedings arc beyond the jurisdiction and the scope of Section 171 of the CGST Act and the DGAP's report is liable to be rejected on this ground alone. N.2 The Respondent placed reliance on the judgment of the Hon'ble Supreme Court in the case of Canara Bank and Others v. Debasis Das and Others reported at (2003) 4 SCC 557, and Uma Nath Pandey and Others v. State of UP reported at (2009) 12 SCC 40. N.3 In view of the foregoing, it is submitted that the present proceedings initiated by NAA against the Respondent without the issuance of a show cause notice violate principles of natural justice and therefore, not sustainable. N.4 The Respondent submitted that he reserves the right to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hree months as allowed by the Authority. Upon completion of investigation, DGAP furnishes a Report to the authority. Therefore, investigation is a time-bound procedure. As soon as the investigation is completed, Report is furnished to the Authority under Rule 129 (6) of the CGST Rules, 2017 but in the instant case due to the prevalent pandemic of Covid 19 in the country, vide Notification no. 91/2020 dated 14.12.2020 it was extended up to 31.03.2021. Further, the Hon'ble Supreme Court of India passed an order dated 08.03.2021 in Suo-motu writ petition(civil) No. 3/2020, wherein, it was stated that in cases where the limitation would have expired during the period between 15.03.2020 till 15.03.2021, notwithstanding the actual balance period of limitation remaining, all persons shall have a limitation period of 90 days from 15.03.2021. In the event, the actual balance period of limitation remaining, with effect from 15.03.2021, is greater than 90 days, that longer period applies . The above relief has been extended and the period from 14.03.2021 till further orders shall also stand excluded in computing the limitation period as per the hon'ble Supreme Court's order dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity is justified and correct. Every recipient/customer is entitled to receive the due benefit of the input tax credit from the supplier. However, one formula which fits all cannot be set while determining such a Methodology and Procedure as the facts of each case are different. In real estate project parameters such as date of start and completion of the project, price of the house/commercial unit, mode of payment of the price, stage of completion of the project, the timing of the purchase of inputs, rates of taxes, amount of ITC availed, total saleable area, area sold and the taxable turnover realized before and after the GST implementation would always be different than the other project and hence the amount of benefit of additional ITC to be passed on in respect of one project would not be similar to another project. Issuance of Occupancy Certificate/ Completion Certificate would also affect the amount of benefit of ITC as no such benefit would be available once the above certificates are issued. Therefore, no set parameters can be fixed for determining methodology to compute the benefit of additional ITC which would be required to be passed on to the buyers of such units. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ary and liable to be set aside. In response to Respondent's claim regarding non-prescription of methodology and procedure, it is stated that the Methodology and Procedure has been notified by the Authority vide its Notification dated 28.03.2018 under Rule 126 of the CGST Rules, 2017. The main contours of the 'Procedure and Methodology' for passing on the benefits of reduction in the rate of tax and the benefit of ITC are enshrined in Section 171 (1) of the CGST Act, 2017 itself which states that Any reduction in the rate of tax on any supply of goods or services or the benefit of the input tax credit shall be passed on to the recipient by way of commensurate reduction in prices. It is clear from the perusal of the above provision that reduction in the rate of tax on any supply of goods or services does not mean that the reduction in the rate of tax is to be taken at the level of an entity/group/company for the entire supplies made by it. Therefore, the benefit of tax reduction has to be passed on at the level of each supply of Stock Keeping Unit (SKU) to each buyer of such SKU and in case it is not passed on, the profiteered amount has to be calculated on ea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot be completed by Authority with in prescribed time limit due to the lack of required quorum of Members in the Authority during the period from 29.04.2021 to 23.02.2022 and the minimum quorum was restored only w.e.f. 23.02.2022. In the present case, both the Respondent and Applicant No. I were given the opportunity for a personal hearing on 09.06.2022 and 16.08.2022. Both Applicant No.1 and Respondent have availed the opportunity of personal hearing and both had provided their submissions. 7. The Authority has examined the case records as discussed above and after taking into consideration the provisions of the law and the submissions made by the Applicant No. 1 and Respondent, the issues to be decided are as under:- a. Whether there was benefit of reduction in the rate of tax or ITC on the supply of construction service by the Respondent on implementation of GST w.e.f. 01.07.2017 and if so, whether such benefit was passed on by the Respondent to the customers/flat-buyers /recipients, in terms of Section 171 of the CGST Act, 2017. b. Whether the Respondent is liable for imposition of penalty under the provisions of Section 171 (3A) of the CGST Act, 2017. c. The is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uct. In the instant case, the Authority finds that the contentions of the Respondent are erroneous as the total benefit passed on may be more in percentage, as compared to the percentage worked out in Report but the Respondent has not passed the benefit of additional ITC commensurately to all the buyers by the way of commensurate reduction prices. The Authority finds that, it is also on record that, the Respondent had claimed to have passed on the ITC benefit to 647 Customers as detailed in his home buyer list submitted vide his email dated 17.09.2020. Such submission of the Respondent was supposedly verified by the DGAP with the home buyers by way of sending e-mails to 344 customers/recipients to ascertain the genuineness of the claim of the Respondent. Out of the 344 e-mails sent, only 86 recipients/customers responded. Out of these 59 recipients/customers had confirmed the receipt of ITC benefit as claimed by the Respondent, 15 recipients/customers had denied the receipt of ITC benefit and 12 recipients/customers had submitted incomplete replies from which no inference could be drawn. As per the said Report, only 59 home buyers/customers/recipients out of all 719 eligible home b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded in the CGST Act, 2017 in case these limits are not observed. The Hon'ble High Court of Delhi while considering the time limit prescribed under Rule 133 (1) vide its order dated 27.01.2020 passed in W. P. (C) 969/2020 in the case of M/s Nestle India Ltd. another. v. Union of India others has ruled as under:- We also observe that prima facie, it appears to us that the limitation of period of six months provided in Rule 133 of the CGST Rules, 2017 within which the Authority should make its order from the date of receipt of the report of the Directorate General of Anti Profiteering, appears to be directory in as much as no consequence of non-adherence of the said period of six months is prescribed either in the CGST Act or the rules framed thereunder. Reliance is also placed on the judgment of the Hon'ble Supreme Court in the case of Mahadev Govind Gharge v. Special Land Acquisition Officer (2011) 6 SCC 321 wherein it was held that:- 37. Procedural laws, like the Code, are intended to control and regulate the procedure of judicial proceedings to achieve the objects of justice and expeditious disposal of cases. The provisions of procedural law which d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he turnovers considered by the DGAP, while calculating the profiteered amount in the present case, are such taxable turnovers only. Hence, the value of land already stands excluded from the calculation of the profiteered amount by the DGAP in its Report. Hence, this contention of the Respondent is not tenable. V. The Respondent has contended that the Comparison of the ratio of input tax credit to turnover for the pre-GST period and GST period is not the correct mechanism for the calculation of profiteering amount. The DGAP has computed the ratio of CENVAT as a percentage of the turnover for the pre-GST period and compared it with the ratio of ITC to the turnover for the post-GST period, and then computed the percentage of the benefit of additional ITC which the Respondent was required to pass on to the flat buyers/recipients. The above ratios had been computed by the DGAP based on the data/details provided by the Respondent and have been duly verified from their Service Tax and GST Returns filed by them for the period April 2016 to June 2017 and July 2017 to December 2018 respectively. Since the ratios calculated by the DGAP are based on the factual record submitted by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ations and findings, the Authority finds that this contention of the Respondent is untenable and hence rejected. VIII. The Respondent has contended that in the absence of prescribed method of calculation of profiteering in the Act or the rules or the procedure, the proceedings are arbitrary and liable to be set aside. The Respondent has questioned the methodology of determination of profiteered amount claiming that that no methodology has been provided under GST laws, for the calculation of the benefits and their distribution. The Authority finds that provisions for passing of the benefits of reduction in the rate of tax and ITC has been outlined in Section 171 (1) of the CGST Act, 2017 itself which provides that Any reduction in rate of tax on any supply of goods or services or the benefit of input tax credit shall he passed on to the recipient by way of commensurate reduction in prices. It is clear from the plain reading of the above provision that it mentions reduction in the rate of tax or benefit of ITC which means that if any reduction in the rate of tax is ordered by the Central or the State Governments or a registered supplier avails benefit of additional IT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... otice, proceedings initiated violate the principles of natural justice. The Respondent has contended that no show cause notice was issued. Whereas it is contended by the DGAP that on receipt of application/complaint, the DGAP had issued notice dated 14.01.2019 to the Respondent to reply as to whether they admitted that the benefit of ITC had not been passed on to the recipient by way of commensurate reduction in the price and furnish supporting documents. Likewise, upon receiving the investigation report, the NAA also issued a notice to the Respondent to show cause why the said report should not be accepted and their liability for profiteering should not be determined under section 171 of the Act. They were directed to file their reply to the findings in the said Report. It may be noted here that DGAP has initiated investigation based on the complaint received from the Applicant and the whole proceedings initiated and investigated by DGAP have been conducted in accordance with the provisions of the law. The DGAP report has come to a prima facie conclusion regarding the amount of the profiteered amount based on the documents and data provided by the Respondent. No rights of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is nil as no post-GST billing during the investigation period was made to Applicant No. 1. 10. Hence, in view of our findings above, the Authority finds no reason to differ from the above detailed computation of profiteered amount by the DGAP or the methodology adopted by it. The Authority determines that the Respondent has profiteered an amount of Rs. 6,89,62,698/-(Rupees Six Crore Eighty-nine Lacs Sixty-two Thousand Six Hundred Ninety-eight only) during the period under present investigation i.e. 1.07.2017 to 31.12.2018, in the present Project. Therefore, given the above facts, the Authority under Rule 133 (3)(a) of the CGST Rules orders that the Respondent shall reduce the price to be realized from the customers/flat buyers/recipients in the Project Godrej 24 commensurate with the benefit of additional ITC received by him as detailed above. 11. The Respondent is also liable to pay interest as applicable on the entire amount profiteered, i.e. Rs. 6,89,62,698/- for the project Godrej 24 . Hence the Respondent is directed to also pass on interest @18% to the customers/ flat buyers/ recipients on the entire amount profiteered, starting from the date from which the above am ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e size to be visible to the public may also be published in a minimum of two local Newspapers/vernacular press in Hindi/English/local language with the details i.e. Name of the builder (Respondent) - M/s Pearlite Real Properties Pvt. Ltd., Project- Godrej 24 , Location- Pune, Maharashtra and profiteered amount Rs. 6,89,62,698/-; so that the Applicant along with Non-Applicants homebuyers/recipients/customers can claim the benefit of ITC which has not been passed on to them. Homebuyers/recipients/customers may also be informed that this detailed NAA Order is available on Authority's website www.naa.gov.in. Contact details of concerned Jurisdictional Commissioner CGST/SGST for compliance of this Authority's order may also be advertised through the said advertisement. 16. Further, this Authority as per Rule 136 of the CGST Rules 2017 directs the concerned jurisdictional CGST/SGST Commissioner shall also submit a Report regarding the compliance of this order to the Authority and the DGAP within a period of 4 months from the date of receipt of this order. 17. Since the Respondent has profiteered in the instant project, there is every likelihood that he has profiteered in o ..... 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