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TMI Blog2020 (11) TMI 105X X X X Extracts X X X X X X X X Extracts X X X X ..... ion, it was also alleged by the Applicant No. 1 that the Respondent did not reduce the selling prices of the DSLR Cameras and Power Banks, when the GST rate was reduced from 28% to 18% w.e.f. 01.01.2019, vide Notification No. 24/201 a-Central Tax (Rate) dated 31.12.2018 and thus, the benefit of reduction in the GST rate was not passed on to the recipients by way of commensurate reduction in the prices. Along with the application, the Applicant No. 1 had also submitted copies of the invoices, report of the jurisdictional Deputy Commissioner (GST) and signed worksheet of the Respondent. 2. The DGAP has also stated that the Standing Committee on Antiprofiteering had examined the aforesaid application and upon being prima facie satisfied, had decided to refer the same to the DGAP to conduct a detailed investigation in the matter in terms of Rule 129 (1) of the CGST Rules, 2017. 3. The DGAP in his Report has further stated that on receipt of the said reference from the Standing Committee on Anti-profiteering on 26.06.2019, a notice under Rule 129 (3) was issued on 12.07.2019, calling upon the Respondent to reply as to whether he admitted that the benefit of reduction in GST rate w.e.f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted the following documents/information:- (a) List of all GSTIN registrations. (b) Copies of GSTR-1 and GSTR-3B Returns for the period from December 2018 to June 2019. (c) Details of invoice-wise outward taxable supplies for the impacted products during the period from September, 2018 to June, 2019. (d) Sample copies of invoices, pre and post 01.01.2019. (e) Total outward sales for the period from December, 2018 to June, 2019. 9. The DGAP has also informed that the reference from the Standing Committee on Anti-Profiteering, the various replies of the Respondent and the documents/evidence on record has been carefully examined. The main issues for determination were whether the rate of GST on the products being supplied by the Respondent was reduced from 28% to 18% w.e.f. 01.01.2019 and if so, whether the commensurate benefit of such reduction in the rate of GST had been passed on by the Respondent to his recipients, in terms of Section 171 of the CGST Act, 2017. 10. The DGAP has further informed that the Central Government, on the recommendation of the GST Council, had reduced the GST rate on the Digital Cameras and Power Banks from 28% to 18% w.e.f. 01.01.2019, vide No ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2.2018 4. Total quantity of item sold C 263 5. Total taxable value D 10515535.70 6. Average base price (without GST) E=D/C 39983.03 7. GST Rate F 28% 18% 8. Commensurate Selling price (post Rate reduction-with GST) G=E*1.18 47179.97 7. Invoice No. H SLA 162030002234 8. Invoice Date I 17.01.2019 9. Total quantity (above invoice) J 1 10. Total Invoice Value K 49460.31 11. Actual Selling price per unit (post rate reduction-with GST) L=K/J 49460.31 12. Excess amount charged or profiteering M=L-G 2280.34 13 Total Profiteering N=M*J 2280.34 12. The DGAP has further mentioned that as per the Table-A, it was clear that the Respondent had not reduced the selling price of the "Canon DSLR 200D Dual Kit (18-55/55-250) Camera", when the GST rate was reduced from 28% to 18% w.e.f. 01.01.2019, vide Notification No. 24/2018 Central Tax (Rate) dated 31.12.2018 and thus, he had profiteered an amount of Rs. 2280.34 on a particular invoice by not passing on the benefit of reduction in GST rate to the recipient by way of commensurate reduction in the pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Telangana 1587602 Grand Total 19121441 16. It has also been intimated by the DGAP that the allegation of the Applicant No. 1 that the base prices of the impacted goods were increased when there was a reduction in the GST rate from 28% to 18% w.e.f. 01.01.2019 and hence, the benefit of such reduction in the GST rate was not passed on to the recipients by way of commensurate reduction in prices stood confirmed against the Respondent as per the details furnished in Annexure-21. Thus, the Respondent by increasing the base prices of the goods subsequent to reduction in the GST rate has not passed on the commensurate benefit of reduction in the GST rate from 28% to 18% to the recipients and thus, he has contravened the provisions of Section 171 of the CGST Act, 2017. Therefore, the total amount of profiteering on account of contravention of the provisions of Section 171 of the CGST Act, 2017 covering the period from 01.01.2019 to 30.06.2019 came out to Rs. 1,91,21,441/-. 17. The above Report was considered by this Authority in its sitting and it was decided to hear the Respondent on 14.01.2020. A notice dated 26.12.2019 was also issued to the Respondent asking him to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed guidelines or methodology for computation of profiteering. e. That the DGAP has considered product level sale prices of December, 2018 month for comparison. The Respondent was engaged in retail business of electronic goods. December was a festive season for the electronic goods retail industry. The Respondent ran various discount schemes and offers with upfront price reductions to lure the customers and increase his sales during this period. Accordingly, during the month of December the sale prices for all the products were generally lowest considering the festive season. Immediately post festive season i.e. upon completion of promotion/discount schemes, base prices of the products were restored to their regular sale prices. While computing the proposed profiteering amount, the DGAP had considered average of such sale prices for the electronic goods sold during December, 2018 (which were lowest on account of discount schemes), for comparison with actual sale prices during the period from January, 2019 to June, 2019 and it had resulted into showing excess profit earned by the Respondent. As per the Report, such apparent excess profit earned had been considered towards profiteer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ttery 18% Entry 376AA: Lithium-ion battery 1 18% 8507 NA Entry 376AAA: Lithiumion accumulators (other than battery) including lithium-ion power banks 18% h. That the Power Bank consisted of lithium-ion battery and circuit such as charge management system and voltage booster. Vide Notification No. 18/2017 dated 26.07.2018, Entry No. 139 was amended and Entry No. 376AA was inserted to levy CST @18% on lithium-ion battery. Accordingly, electric accumulators other than lithium-ion battery continued for GST levy @ 28%. Subsequently, vide Notification No. 24/2018 dated 31.12.2018, Entry No. 139 was further amended and Entry No. 376AAA was inserted to levy CST @ 18% on lithium-ion based Power Banks. Accordingly, electric accumulators other than lithium ion battery and lithium-ion based Power Banks continued for GST levy @ 28%. During the period from 26.07.2018 to 31.12.2018, there was an ambiguity with respect to classification of Power Banks under lithium-ion battery (GST @ 18%) or under other accumulators (GST @ 28%). Thus, vide Notification No. 24/2018 dated 31.12.2018, the Government acknowledged the said ambiguity in classification of the Power Banks. Accordingly, lithiu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , competition pricing, e-commerce platform pricing, cost of the products, tax cost involved and other variable expenses etc. The proposed profiteering to the extent of Rs. 85,92,356/- has been computed erroneously, as important parameters have not been considered. Accordingly, the proposed profiteering amount of Rs. 1,91,21,441/- needed to be reduced by Rs. 85,92,356/-. l. That while computing profiteering, the DGAP has not considered the following important parameters which are required to be taken in to account:- Table Sr.No. Particular Proposed demand amount (Amount in INR) Annexure 1. Para 14.1-Excess GST collected has been paid to Government 29,16,750 Annexure I 2. Para 14.2-Sales return (credit notes) towards sales invoices issued during January 2019 to June 2019 not considered 28,75,832 Annexure II 3. Para 14.3 - Sale of goods with taxable sales price below cost of purchase 13,13,441 Annexure III 4. Para 14.4 - Sale of goods with comparable sales price below the cost of purchase 14,86,332 Annexure IV Total 85,92,356 m. That the excess CST collected and paid to Government had been erroneously included in the proposed demand towards ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the DGAP and had been ignored while computing the profiteering amount. A summary of the sale returns transactions has been furnished by the Respondent as has been mentioned below:- Period Credit note (taxable value) Credit note (GST) Credit Note (total value) Profiteering demand January 2019 to June 2019 7,15,86,988 1,28,85,656 8,44,72,645 28,75,832 p. That issuance of the credit notes has resulted into cancelation of the sale transactions. Accordingly, there could not be profiteering with respect to parent invoices for which credit notes had been issued and transactions had been cancelled. The Respondent has mentioned the credit notes issued against the sale invoices issued during January, 2019 to June, 2019 and reduction in the alleged demand to that extent as per Annexure-I and therefore, he has requested that the proposed demand to the extent of INR 28,75,832/should be dropped. q. That the Respondent was engaged in the business of retail sale of electronic products. With respect to electronic products, technology got upgraded on a regular basis. In order to clear the inventory of non-moving or obsolete technology products, the Respondent was selling the said produ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and the total proposed demand of Rs. 85,92,356/- had been wrongly computed in the Report which needed to be dropped. 19. Supplementary report was sought from the DGAP on the issues raised by the Respondent vide his above-mentioned submissions dated 03.02.2020 and the DGAP vide his Report dated 27.02.2020 has stated:- a. That every supplier of goods and services was free to increase the price of his supply depending upon the various components affecting the cost of production/supply. But under the provisions of Section 171 of the CGST Act, 2017, no supplier could increase the base prices of the products overnight in such a manner that even with reduction in the rate of tax, the cum-tax selling price would remain unchanged. Section 171 (1) of the CGST Act, 2017 was very clear which stated that any reduction in the rate of tax or the benefit of input tax credit had to be passed on to the recipients by way of commensurate reduction in prices. b. That the contention of the Respondent that the prices of his products were lower due to the festival season during December, 2018 was frivolous and unacceptable. Firstly, the contention of the Respondent appeared to be an afterthought as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he benefit of reduction in tax rate by not reducing the prices of the products commensurately. d. That with the implementation of GST w.e.f. 01.07.2017, the Government vide Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017 had prescribed a GST rate of 28% on the goods listed in Schedule IV of the said Notification. As per Sl. No. 139 of Schedule IV, the goods described as "Electric accumulators, including separators thereof, whether or not rectangular (including square)" falling under Chapter Heading 85.07 attracted GST rate of 28%. Later on, vide Notification No 18/2018 Central Tax (Rate) dated 26.07.2018, the description of goods mentioned against Entry No. 139 (Chapter Heading 85.07) was substituted as "Electric accumulators, including separators thereof, whether or not rectangular (including square) other than Lithium-ion battery "The said Notification inserted an Entry No. 376AA in Schedule Ill for "Lithium-ion batteries" classifiable under Chapter Subheading 8507 60 00. By this insertion in Schedule Ill, Lithium-ion batteries became chargeable to 18% GST. In December 2018, further amendment was made vide Notification No. 24/2018 Central Tax (Rate) dated 31 .12.20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Rule 126 of the CGST Rules, 2017, this Authority had been empowered to determine the methodology and procedure for determination as to whether the reduction in the rate of tax or the benefit of ITC had been passed on by the registered person to the recipients by way of commensurate reduction in prices, The extent of profiteering had to be arrived at on a case to case basis, by adopting suitable method based on the facts and circumstances of each case as well as the nature of goods or services supplied. There could not be any uniform methodology for determination of the quantum of benefit to be passed on. However, this Authority had already notified the 'Methodology and Procedure' under Rule 126 on 28.03.2018. Moreover, the intent of Section 171 of the CGST Act, 2017 was not to administer/fix the sale prices as it nowhere sought to fix the prices at which the goods and services ought to have been supplied. The said Section only required the supplier to pass on the benefit of reduction in the rate of tax or the benefit of ITC to the recipients by reducing the prices commensurately and did not require him to seek any approval to conduct trade or fix prices of the products supplied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tes and adjusting his tax liability for the subsequent period to that extent. Therefore, it was clear that the profiteered amount would also include the excess tax (GST) paid by the customers/recipients. h. That the Respondent had submitted the details of sale returns during the investigation and the same were duly considered by the DGAP in his Report. Accordingly, the sales return data was excluded from the profiteering sheet and the same could be verified from the profiteering excel sheet annexed with the Report dated 23.12.2019 submitted by the DGAP. i. That the claim of the Respondent that he had sold his products at the price lower than their cost was incorrect. In this regard, first entry of the Annexure - II submitted by the Respondent has been illustrated by the DGAP in the following Table:- Invoice No. SLA163030000438 Invoice Date 03.01.2019 Goods Description Power Bank Quantity 1 Type of sale Normal Discount, if any ----- Base selling price (commensurate) 385.94 Base selling price (actual) 418.64 Cost price 774.03 Upon perusal of the above Table, it could be seen that the base selling price (commensurate) arrived at by the DGAP was based on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 23.12.2019, providing computation of proposed demand which did state credit note transactions details in Column 'T', however, the DGAP had missed to provide adjustment of tax reversal on credit notes towards invoices issued during the period from 01.01.2019 to 30.06. 2020 as has been shown hereunder:- Gross profiteering demand without giving adjustment of sales return (Column 'U' to 'Y') Gross profiteering demand if adjustment of sales return is given INR 1,91,20,911 INR 1,57,27,429 If the said adjustment towards sales return (credit notes) was provided, then proposed demand should be reduced by Rs. 33,93,482/- (gross with tax) / Rs. 28,75,832/- (net without tax) as per Annexure-A. Accordingly, the said demand should be dropped. c. That at the outset, the Respondent had not challenged the computation of the average sale prices computed for December, 2019. It was also submitted that the technology of the electronic products under consideration i.e. Digital Cameras and Power Banks had been upgraded frequently. The products under consideration were old technology products, whose stock could not be sold due to technology upgrade. In order to sell the stock of the said goods, it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the extent of alleged gross profiteering amounting to Rs. 11,09,736/- (Net profiteering amounting to Rs. 9,40,454/-) needed to be dropped. In support of his claim, the Respondent has submitted (Annexure-C) sale transactions alongwith transaction level cost (Annexure-3), excel worksheet as well as screenshot from the SAP system confirming the invoice wise sale value and cost mentioned in Annexure-3, SAP screenshot of cost movement (moving average cost) for sample transactions mentioned in Annexure-3 and sample purchase invoices in support of cost amount mentioned in Annexure-3. f. That vide submissions dated 03.02.2020 (Paras 4, 5, 6, 7, 8, 9, 10, 11, 12 and 13), it was submitted that the sale prices of the products during the period under consideration were determined after taking into consideration various commercial factors (such as demand vs supply, pricing adopted by competition and e-commerce operator, technology, slow moving / non-moving inventory status, season discount / pricing, promotion/discount offers etc.) as well as the tax rate change and it was requested to consider the commercial factors as well while computing the impact of tax rate change, instead of computi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n in the price of the goods or services of both." 23. It is also observed from the record that the Respondent is engaged in retail trading of electronic goods from his stores under the brand name 'CROMA'. It is also revealed from the plain reading of Section 171 (1) of the CGST Act, 2017 that it deals with two situations one relating to the passing on the benefit of reduction in the rate of tax and the second about the passing on the benefit of the ITC. On the issue of reduction in the tax rate, it is apparent from the record that there has been a reduction in the rate of tax from 28% to 18% w.e.f. 31.12.2018, on the Digital Cameras and Power Banks being supplied by the Respondent, vide Notification No. 24/2018-Central Tax (Rate) dated 31.12.2018. Therefore, the Respondent is liable to pass on the benefit of tax reduction to his customers in terms of Section 171 (1) of the above Act. It is also apparent that the DGAP has carried out the present investigation w.e.f. 01.01.2019 to 30.06.2019. 24. It is also evident that the Respondent has been selling different variants of Digital Cameras and Power Banks during the period from 01.01.2019 to 30.06.2019 to his customers. Upon compari ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... store and period to period. Therefore, the average pre rate reduction prices of 153 products were computed by the DGAP, which were being sold by the Respondent, as is evident from the Annexure-21 attached with his Report, on the basis of which commensurate base prices post rate reduction were calculated in respect of the same products and compared with the invoice wise post rate reduction actual base prices of these products, as per the computation illustrated in Table-A supra. The average pre rate reduction base price of each product was required to be compared with the actual post rate reduction base price of the same product as the benefit was required to be passed on each product to each customer. In case average to average base price is compared for both the periods, the customers who have purchased a particular product on the base price which is more than the commensurate base price, would not get the benefit of tax reduction. Such a comparison would be against the provisions of Section 171 as well as Article 14 of the Constitution which require that each customer has to be passed on the benefit of tax reduction on each purchase made by him. On the basis of the aforesaid pre ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e above Governments out of their scarce and precious tax revenue. It also provides that the above benefits are to be passed on any supply i.e. on each Stock Keeping Unit (SKU) of each product or unit of construction or service to every buyer and in case they are not passed on, the quantum of denial of these benefit or the profiteered amount has to be computed for which investigation has to be conducted in respect of all such SKUs/units/services by the DGAP. What would be the 'profiteered amount' has been clearly defined in the explanation attached to Section 171 quoted above. These benefits can also not be passed on at the entity/organisation/branch/invoice/product/business vertical level as they have to be passed on to each and every buyer at each SKU/unit/service level by treating them equally. The above provision also mentions "any supply" which connotes each taxable supply made to each recipient thereby making it evident that a supplier cannot claim that he has passed on more benefit to one customer on a particular product therefore he would pass less benefit or no benefit to another customer than what is actually due to that customer, on another product. Each customer is entit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... urnover received before and after the GST implementation would always be different from 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 the other project. Therefore, no set procedure or mathematical methodology can be framed for determining the benefit of additional ITC which has to be passed on to the buyers of the units. Moreover, this Authority under Rule 126 has been empowered to 'determine' Methodology & Procedure and not to 'prescribe' it. Similarly, the facts of the cases relating to the sectors of Fast Moving Consumer Goods (FMCG), restaurant service, construction service and cinema service are completely different from each other and therefore, the mathematical methodology adopted in the case of one sector cannot be applied to the other sector. Moreover, both the above benefits are being given by the Central as well as the State Governments as a special concession out of their tax revenue in the public interest and hence the suppliers are not required to pay even a single penny from their own pocket and therefore, they are bound to pass on the above benefits as per the provisions of Secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... duction to the customers only and have no mandate to look into fixing of prices of the products which the Respondent is free to fix. If there was an increase in his costs the Respondent should have increased his prices before 01.01.2019, however, it cannot be accepted that his costs had increased exactly on the intervening night of 31.12.2018/ 01.01.2019 when the rate reduction had happened which had forced him to increase his prices exactly equal to the reduction in the rate of such tax. Such an uncanny coincidence is unheard off and hence there is no doubt that the Respondent has increased his prices for appropriating the benefit of tax reduction to deny the above benefit to the customers. 28. The Respondent has also contended that during the month of December, the sales prices of the products were generally lowest as December was a festive season month. The DGAP has considered the average sale prices of the products during the month of December, 2018 for comparison with the actual sales prices during the period from 01.01.2019 to 30.06.2019 which has resulted in excess profit which has been considered profiteering. In this context, it would be pertinent to mention that one or t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd in order to clear the stock of the same, the Respondent had been selling the said products below the cost prices or at the sale prices lower than the regular sale prices resulting in loss or nominal profits. As per the books of accounts the total profit earned from the sale of the digital cameras was equivalent to the alleged profiteering amount of Rs. 1,41,38,205/- which established that there was no profiteering. In this respect it would be appropriate to mention that the Respondent has not produced invoices or other evidence during the course of the present proceedings to establish that he has sold the cameras on the prices which were lower than their purchase cost. Earning of less profit or no profit also has no correlation with the profiteered amount. The profit earned depends upon the costs of the Respondent which can always be inflated by him whereas the profiteered amount pertains to the amount of tax reduction which has not been passed on by the Respondent. Further, the loss making concerns are also legally bound to pass on the benefit of tax reduction and they cannot appropriate the same against their losses. Therefore, the above claim of the Respondent is not tenable. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e customers. Therefore, the above averment of the Respondent cannot be accepted. 33. The Respondent has also argued that while determining the average base prices of the products sold during the month of December, 2018 the DGAP has completely ignored business factors impacting the sale prices of the impacted products and the discount schemes run by the Respondent. Thus, profiteering to the extent of Rs. 85,92,356/- should be reduced from the proposed profiteered amount of Rs. 1,91,441/-. The above contention of the Respondent is not correct because the investigation carried out by the DGAP reveals that the profiteering has been computed on the transaction value of the products as per the provisions of Section 15 of the CGST Act, 2017 and therefore, all the discounts which do not form part of such value have not been included in the computation of the pre rate reduction average base prices of the products. Therefore, there has been no impact of the business factors or the discount schemes on the calculation of the pre rate reduction average base prices of the products sold by the Respondent. The Respondent has also not produced any evidence to show that due to the business factors ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... annot be accepted. Accordingly, an amount of Rs. 29,16,750/- collected as excess GST cannot be reduced from the profiteered amount. 35. The Respondent has also contended that while calculating the profiteering, the DGAP has not considered the Sale Returns transactions i.e. credit notes issued by the Respondent towards the sales transactions which were retuned by the recipients for the period from January 2019 to June 2019. If the sales return transactions were considered, the profiteered amount would be reduced by Rs. 28,75,832/-. He has also submitted details of the sale returns as per Annexure-A attached to his submissions dated 23.06.2020. In this connection, it would be pertinent to mention that the DGAP vide his supplementary report dated 27.02.2020 has stated that the details of sale returns were submitted by the Respondent during the course of the investigation and the same have duly been considered by him in his Report dated 23.12.2019. Accordingly, the sale returns data was excluded from the profiteering sheet and the same could be verified from the excel sheet of profiteered amount annexed with the DGAP's above Report. Upon perusal of the excel sheet submitted by the DG ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Similar claims have been made by him in respect of other products also. The Respondent has not produced any evidence during the course of the present proceedings which can establish the exorbitant moving cost prices claimed by the Respondent. The screen shots of the SAP system can also not be accepted as the conclusive proof of the cost movement as the Respondent is free to make any entries in the above system as per his convenience. It will also be pertinent to mention here that the pre rate reduction base prices included all the costs which the Respondent had borne while selling these products and hence, the Respondent cannot invent additional costs to be taken in to account while computing the profiteered amount. There is also no evidence on record to show that the sales made by the Respondent were on discount as all the sales mentioned in Annexure-Il were normal sales as has been admitted by the Respondent himself vide Annexure-B. Therefore, the above claim of the Respondent is unreasonable, unsubstantiated and far-fetched which cannot be accepted, hence an amount of Rs. 13,13,441/- cannot be reduced from the profiteered amount on this ground. 37. The Respondent has also cla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n Annexure-21 of the DGAP's Report dated 23.12.2019. Accordingly, the Respondent is directed to reduce his prices commensurately, as indicated in the above mentioned Annexure, in terms of Rule 133 (3) (a) of the above Rules. The Respondent is also directed to deposit an amount of Rs. 1,91,21,441/- in two equal parts each in the Central Consumer Welfare Fund and the Consumer Welfare Funds of the States/UTs mentioned supra as per the provisions of Rule 133 (3) (c) of the above Rules, since the recipients are not identifiable. The above amounts shall be deposited along with 18% interest payable from the dates from which the above amount was realized by the Respondent from his recipients till the date of deposit in the Consumer Welfare Funds. The above amount of Rs. 1,91,21,441/-, along with applicable interest thereon, shall be deposited within a period of 3 months from the date of passing of this order failing which it shall be recovered by the concerned CGST/SGST Commissioners as per the provisions of the CGST/SGST Acts. 39. This Authority as per Rule 136 of the CGST Rules 2017 directs the concerned Commissioners of CGST/SGST to monitor this order under the supervision of the DGAP ..... X X X X Extracts X X X X X X X X Extracts X X X X
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