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TMI Blog2021 (1) TMI 844X X X X Extracts X X X X X X X X Extracts X X X X ..... o. 46/2017-Central Tax (Rate) dated 14.11.2017 without the benefit of ITC. 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 present investigation has been carried out w.e.f. 15.11 .2017 to 30.06.2019. It is also evident that the Respondent has been dealing with a total of 137 items during the period from 15.11.2017 to 30.06.2019. The DGAP has reported that the GST rate of 5% has been charged w.e.f. 15.11.2017 however the base prices of 133 products have been increased more than their commensurate prices w.e.f. 15.11.2017 which establishes that because of the increase in the base prices the cum-tax prices paid by the consumers were not fixed commensurately, despite the reduction in the GST rate. As per the provisions of Sec 171 (1) read with Rule 133 (1) the profiteered amount is determined as ₹ 6,85,531/- as has been computed in Annexure-15 of the DGAP s Report dated 27.12.2019. Accordingly, the Respondent is directed to reduce his prices commensurately in terms of Rule 133 (3) (a) of the above Rules. Further, since the recipients of the benefit, as det ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Maharashtra State Screening Committee on Antiprofiteering alleging profiteering in respect of restaurant service supplied by the Respondent despite the reduction in the rate of GST from 18% to 5% w.e.f. 15.11.2017 vide Notification No. 46/2017-Central Tax (Rate) dated 14.11.2017 by way of not making a commensurate reduction in price, in terms of Section 171 of the CGST Act, 2017. 2. The aforesaid issue was examined by the Maharashtra State Screening Committee on Anti-profiteering which observed that the Respondent had not passed on the benefit to his customers on account of reduction in tax rate and forwarded the complaint to the Standing Committee on Anti-profiteering for further action. 3. The Standing Committee on Anti-profiteering examined the reference received from the Maharashtra State Screening Committee in its meeting held on 15.05.2019 and it was decided to refer the matter to the DGAP to initiate an investigation and collect the evidence necessary to determine whether the benefit of reduction in the rate of GST on the supply of restaurant service had been passed on by the Respondent to the recipients. The Assistant Commissioner of Sales Tax (D-819), Nodal Divisi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... questing him to submit the remaining documents but vide his letter dated 04.11.2019 he informed that his system had crashed in the month of January, 2018 and the data was lost completely from the Subway system and even the headquarters of M/s. Subway Systems India Pvt. Ltd. was not able to fetch the details and expressed his inability to submit the requisite documents/information. 7. Vide Letters/e-mails dated 10.12.2019 and 16.12.2019, the DGAP requested the Respondent to submit a letter of undertaking /affidavit with regard to non-availability/recovery of data up to January, 2018 and to furnish a copy of the correspondence and e-mails exchanged with Subway headquarters and with service providers to recover the lost data to ascertain the veracity of the claims made by him. However, the Respondent failed to respond to the above communications. 8. In response to the Notice dated 09.07.2019 and subsequent reminders vide letter/e-mails dated 23.07.2019, 02.08.2019, 20.08.2019, 02.09.2019, 31.10.2019, 10.12.2019, 16.12.2019 and summons dated 19.09.2019 and 27.09.2019, the Respondent submitted his replies vide e-mails/letters dated 22.07.2019, 19.08.2019, 26.08.2019, 30.08.2019, 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... estigation. The DGAP has further submitted that the Respondent had tried to delay the investigation by not submitting the requisite documents and by requesting for repeated extensions of time for submitting his data in each of his replies; further the Respondent had not submitted the invoice-wise details of his outward taxable supply during the period from 01.07.2017 to 31.01.2018, in the absence of which, the DGAP had requested the Respondent to map the Menu product names in the Sale register to determine the number of units of each of the products sold by him; further, the Respondent neither responded to the DGAP on this issue nor did he submit the desired information/documents. 11. The DGAP has also reported that the reference received from the Standing Committee on Anti-profiteering, the various replies of the Respondent and the documents/evidence on record were carefully scrutinized. The main issues to be examined in the investigation were whether the rate of GST on the service supplied by the Respondent was reduced from 18% to 5% w.e.f. 15.11.2017 and if so, whether the benefit of such reduction in the rate of GST had been passed on by the Respondent to his recipients/ cus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7. As per the details submitted by the Respondent for the period before 14.11.2017, the increase in base prices after the reduction in GST rate w.e.f. 15.11.2017 was evident in respect of 133 items (97.08% of 137 items) supplied by him. This increase in the base price was mentioned in the report by the DGAP. The lower GST rate of 5% had been charged on the increased base price of these 133 items, which confirmed that the tax amount was computed @ 18% before 15.11.2017 and @ 5% w.e.f. 15.11.2017. However, the fact was that because of the increase in base prices the cum-tax price paid by the consumers was not reduced commensurately for all the items supplied by the Respondent. Therefore, the issue to be investigated was whether the increase in base prices was solely on account of the denial of ITC or not. 15. The DGAP has also reported that the assessment of the impact of denial of input tax credit which was an uncontested fact required determination of the ITC in respect of restaurant service as a percentage of the taxable turnover from the outward supply of products during the pre-GST rate reduction period. To illustrate, if the ITC in respect of restaurant service was 10% o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect from 15.11.2017, when the GST rate on restaurant service was reduced from 18% to 5%, the said ITC was not available to the Respondent. A summary of the computation of the ratio of ITC to the taxable turnover of the Respondent was furnished by the DGAP as is given in Table below: Table (Amount in Rs.) Particulars July 2017 August 2017 September 2017 October 2017 Total ITC Availed as per GSTR-3B(A)* 1,18,312 1,27,319 1,07,139 1,01,964 4,54,734 Total Outward Taxable Turnover as per GSTR-3B (B) 11,45,395 11,43,249 12,90,075 11,40,264 47,18,983 The ratio of ITC to Net Outward Taxable Turnover (C)= (A/B) 9.64% 9.64% 17. The DGAP has further mentioned that the analysis of the details of item-wise outward taxable supplies during the period from 15.11.2017 to 30.06 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... item was compared with the actual cum-tax selling price of this item as per Menu Price List during post- GST rate reduction i.e. on or after 15.11.2017 as has been illustrated by the DGAP in the Table below: Table (Amount in Rupees) Sl.No. Description Factors Pre Rate Reduction (up to 14.11.2017 Post-tax rate Reduction (From 15.11.2017) 1. Item Description and Category A Western Egg and Cheese (6 INCH) 2. Base price as per Menu Price List B 110/- 3. GST@ 18% C=B*18% 19.80/- 4. Selling price (including GST) D=B+C 129.80/- 5. GST Rate E 18% 5% 6. Denial of ITC of 9.64% as per table- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dit) or in other words, the profiteered amount came to ₹ 6,85,531/- (including GST on the base profiteered amount). The detailed computation of the above amount was given in the Annexure-15 of the Report. 22. Based on the details of outward supplies of the restaurant service submitted by the Respondent, the DGAP has observed that the said service had been supplied by the Respondent in the State of Maharashtra only. 23. The DGAP has further stated that the allegation of profiteering by way of either increasing the base prices of the products or by way of not fixing the selling prices of the products commensurately, despite the reduction in GST rate from 18% to 5% w.e.f. 15.11.2017 stood established against the Respondent. On this account, the Respondent had realized an additional amount to the tune of ₹ 6,85,531/- from the recipients which included both the profiteered amount and GST on the said profiteered amount. 24. The DGAP has also reported that Section 171 (1) of the CGST Act, 2017 requiring that any reduction in rate of tax on any supply of goods or services or the benefit of ITC shall be passed on to the recipient by way of commensurate reduction in p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... roducts was incorrect as it rested on the assumption that the ITC to taxable turnover ratio for the pre-tax rate reduction period would be the same as the ITC to taxable turnover ratio for the post-tax rate reduction period; that the DGAP has erroneously considered the ITC availed instead of the ITC utilized for the computation of the ratio of ITC to the taxable turnover for pre-tax rate reduction period; that the DGAP should have taken utilized ITC up to 14.11.2017 as the Respondent could utilize the ITC only up to 14.11.2017 for the payment of ax on outward supplies. Therefore, the period from 01.11.2017 to 14.11.2017 should have not been excluded from the calculation of ITC to the taxable turnover ratio. b. That the DGAP has not taken into account the ITC and the taxable turnover for the period from 01.11.2017 to 14.11.2017; that the total ITC availed by him during the period from 01.07.2017 to 14.11.2017 was ₹ 5,26,236/- and his taxable turnover for this period as per GSTR-3B return was ₹ 53,37,603.77/-; that thus the correct ITC availed to taxable turnover ratio for the pre-tax rate reduction in his case worked out to 9.86% [(5,26,236/53,37,603.77*100] and not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... per the assessment of his franchisor (SSIPL), the average impact of the withdrawal of ITC was about 11%. e. That he had increased the base prices of the items supplied as sub of the day (SOTD items) by only 8.22% and this was well within the permissible increase of the 9.64% calculated by the DGAP; that in the case of the item supplied as classy combo the base price had been reduced by him by 4.76%; that thus, in respect of items sold as SOTD and the item clay combo , there was no profiteering; that in the case of other items, except the item supplies as wraps , the base prices were increased by him and the said increase was ranging from 10.70% to 14.69%; that in the case of the item wraps , which was supplied in small quantities, the increase in the base price ranged from 17.39% to 20.34%; that thus the average increase in his base prices was 10.80%; that hence he had not profiteered since he had not retained the benefit of the reduction in the rate of tax. f. That during the financial year 2018-19, the rise in the cost of some of his major inputs, viz. salary staff welfare, rent, electricity and material cost was 9.32%, 28.46%, 5.42%, and 5%, respectively, whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the CGST Rules 2017 was there any provision prescribing the following:- (i) How to determine that a supplier had not passed on the benefit of reduction in the rate of tax or ITC by way of commensurate reduction in prices and how would it be determined that an increase in the base price after a reduction in the rate of tax or a non- reduction of the base price on account of higher ITC benefit was not due to genuine and bona fide reasons like increase in the cost of inputs, etc; (ii) In case if the reduction in the rate of tax was accompanied by a withdrawal of ITC, how would the impact of the withdrawal of ITC benefit on prices during the post-tax rate reduction period be calculated; and (iii) In case if profiteering has been established, what should be the period of investigation and how long would be the period after which the price could be reduced; whether it would be considered if the effect of reduction in the rate of tax was neutralized by other factors affecting the price, such as an increase in the cost of inputs, spurt in the demand, etc. i. That the DGAP has not provided any specific reason for adopting an arbitrary and long period of investig ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Respondent were forwarded to the DGAP vide this Authority s Order dated 10.02.2020 asking him to file clarifications thereon under Rule 133 (2A) of the CGST Rules, 2017. Accordingly, the DGAP has filed clarifications vide his communications dated 28.02.2020, 29.05.2020, and 17.07.2020, which have been summed up as follows:- a. On the contention of the Respondent that the DGAP s calculation of the ratio of ITC availed to the taxable turnover for the pre-tax rate reduction period was incorrect and the connected contention related to the non-consideration of the ITC and taxable turnover for the 01.11.2017 to 14.11.2017 period by the DGAP, the DGAP has reported that the Ratio of Input Tax Credit to Net Outward Taxable Turnover was 9.64% in the pre-tax rate reduction period and hence the Respondent could have increased the base price by 9.64% in the post-tax rate reduction period, i.e. after 15.11.2017 to negate the impact of the denial of ITC. However, it was clear that the Respondent has increased the base prices of his 115 impacted items by more than what was required to offset the impact of denial if ITC. Thus, the total profiteered amount worked out to ₹ 6,85,531/- for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... franchisor, who determined the price and that thus he had not contravened the provisions of Section 171(1) of the CGST Act, 2017, the DGAP has stated that the said contention of the Respondent was bereft of factual grounds since he was an independent GST registrant, having a separate GSTIN registration, and he had been availing ITC as an independent entity before and after 15.11.2017; that in terms of Section 171 of CGST Act, 2017, the legal requirement was that in the event of a benefit of input tax credit or reduction in the rate of tax, there must be commensurate reduction in prices of the goods or service and that such a reduction could only be in absolute/ monetary terms so that the final price payable by any consumer in respect of each supply got reduced. The DGAP has added that this was the only legally prescribed mechanism for passing on the benefit of input tax credit or reduction in the rate of tax under the GST regime to the consumers since Section 171 of the ACT simply did not provide a supplier of the goods or services any other means of passing on the benefit of ITC or reduction in the rate of tax to the consumers. The DGAP has also added that therefore the computatio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TMI 760 - NATIONAL ANTI-PROFITEERING AUTHORITY . cited by the Respondent was different from the instant case as in the case of M/s. KRBL the pre-GST rate was nil and for the first time, a tax rate of 5% was imposed on the impugned product. i. On the contention of the Respondent that the element of GST has been added to the base profiteered amount in the computation incorrectly since the same has already b n deposited as CGST and SGST, the DGAP has clarified that Section 171 of the CGST Act, 2017 and Chapter XV of the CGST Rules, 2017 required the supplier of goods or services to pass on the benefit of the tax rate reduction to the recipients by way of a commensurate reduction in the price. Price included both, the base price and the tax paid on it. If any supplier has charged more tax from the recipients, the aforesaid statutory provisions would require that such amount be refunded to the eligible recipients or deposited in the Consumer Welfare Fund, regardless of whether such extra tax collected from the recipient has been deposited in the Government account or not. Besides, any extra tax returned to the recipients by the supplier by issuing a credit note could be declared ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tigation has been carried out w.e.f. 15.11 .2017 to 30.06.2019. 29. It is also evident that the Respondent has been dealing with a total of 137 items during the period from 15.11.2017 to 30.06.2019. The DGAP has reported that the GST rate of 5% has been charged w.e.f. 15.11.2017 however the base prices of 133 products have been increased more than their commensurate prices w.e.f. 15.11.2017 which establishes that because of the increase in the base prices the cum-tax prices paid by the consumers were not fixed commensurately, despite the reduction in the GST rate. 30. It is pertinent to mention that the method of computation of profiteering on the basis of comparison of item-wise average pre-rate reduction base prices with the actual post-rate reduction base prices for determination of profiteered amount as approved by this Authority in the cases of tax reduction cannot be applied in this case because of the following reasons: a. That despite repeated requests and reminders issued by the DGAP, the Respondent had not submitted the invoice wise details of his outward taxable supplies for the period from 01.07.2017 to 31.01.2018 and had instead submitted that his software sy ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Respondent to provide the relevant information in the prescribed format to the DGAP which formed the basis of computation of product-wise base prices for the period from 01.11.2017 to 14.11.2017, was also a reason for consideration of the Menu Price List for computation of the profiteered amount. Since the invoice wise details of the supplies for the pre-rate reduction period w.e.f. 01.11.2017 to 14.11.2017 and the post-rate reduction period w.e.f. 15.11.2017 to 30.06.2019 were not supplied due to the malafide intentions of the Respondent therefore, the average pre-rate reduction base prices could not be computed and compared with the actual post-rate reduction base prices, especially when there was clear evidence that the Respondent had contravened the provisions of Section 171 by increasing the base prices of his products on the intervening night of 14.11.2017, when the rate reduction took place, the DGAP had no other option but to compare the Menu Price Lists of the pre-rate reduction and post-rate reduction periods for computation of profiteered amount. It is further clear to us that this deliberate action of the Respondent to withhold the requisite data cannot be allo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce between pre-rate change cum-tax selling price and post-rate change selling price has been established as profiteered amount. 32. It is further revealed from the analysis of the details of item-wise outward taxable supplies made during the period from 15.11.2017 to 30.06.2019 that the Respondent had increased the base prices of different items supplied as a part of restaurant service to make up for the denial of ITC post GST rate reduction. The pre and post GST rate reduction prices of the items, as per Menu Price Lists, have been compared and it has been found that the Respondent has increased the base prices by more than 9.64% i.e. by more than what was required to offset the impact of denial of ITC in respect of 115 items sold during the above period. Thus, it is apparent that the Respondent has resorted to profiteering as the commensurate benefit of reduction in the rate of tax from 18% to 5% has not been passed on by him. However, there was no profiteering in respect of the remaining items on which there was either no increase in the base prices or the increase in base prices was less or equal to the denial of ITC or these were new products launched post-GST rate reductio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nvoices for the period from 01.11.2017 to 14.11.2017 during the currency of present proceedings before this Authority in pdf format which ran into thousands of pages, from which relevant information could not be extracted for determination of profiteered amount. In this regard, it is pertinent to mention that the Respondent had desisted from furnishing the said invoices during the investigation on one pretext or the other despite numerous reminders issued by the DGAP. We also find it pertinent to mention that the failure of the Respondent to provide the relevant information in the prescribed format to the DGAP that allowed computation of product-wise base prices for the period from 01.11.2017 to 14.11.2017 was also a reason for the exclusion of the month of November 2017. The Respondent had also not reversed the balance ITC that he ought to have done in line with the existing statutory provisions. It is also pertinent that the DGAP or this Authority cannot be forced to reconcile each entry made in the invoices in the pdf format and then ascertain the amount of taxable supply of the Respondent for the period 01.11.2017 to 14.11.2017. Therefore, we agree with the view of the DGAP th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dent has not submitted any cogent evidence to prove that the prices of the products supplied by him are controlled by M/s. Subway Systems India Pvt. Ltd. and that he, was not free to fix the prices of his products. In this context, we also note that the provisions of Section 171 of the CGST Act, 2017 require a registered person to pass on the benefit of additional ITC or reduction in the rate of tax by way of a commensurate reduction in the prices of the goods or services supplied by him. It is also pertinent that it was the Respondent who had been availing ITC and not the franchisor. Hence, in the present case, it was clearly the responsibility of the Respondent to comply with the provisions of Section 171 of the CGST Act, 2017 and the said responsibility could not be shifted to any other person, including the Franchisor. Therefore, the contention made by the Respondent is not correct and hence dismissed. 38. The Respondent has further contended that the right to trade was a fundamental right guaranteed under Article 19 (1) (g) of the Constitution of India and the right to trade incorporated the right to determine prices which could not be taken away without any explicit author ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his supplies only for appropriating the benefit of tax reduction to deny the above benefit to the consumers. 40. The Respondent has also relied upon the decision of this Authority given in the case of Kumar Gandharv v. M/S KRBL Limited (Case Number 03/2018 dated 04.05.2018 = 2018 (5) TMI 760 - NATIONAL ANTI-PROFITEERING AUTHORITY) to support his case. In this context, it is pertinent to mention that in the above case no benefit of the increase in the cost was given. Instead, the rate of tax had been increased from 0% to 5% on the product under consideration and hence the provisions of Section 171 (1) were not applicable as there was no tax reduction. Therefore, the facts of the above case are different from this case and hence, they cannot help the Respondent. 41. One of the contentions made by the Respondent is that the CGST Act and the Rules made thereunder did not prescribe any procedure or mechanism for calculation of profiteering due to which the DGAP had arbitrarily adopted a methodology that best suited his motives. In terms of Section 171 (3) of the above Act, this Authority could discharge only such function and exercise such powers as were specifically mentio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction in prices is purely a mathematical exercise which is based upon the above parameters and hence it would vary from SKU to SKU or unit to unit and hence no fixed methodology can be prescribed to determine the amount of benefit which a supplier is required to pass on to a recipient or for computation of the profiteered amount. However, to give further elaborate upon this legislative intent behind the law, this Authority has been empowered to determine the Procedure and Methodology which has been done by this Authority vide its Notification dated 28.03.2018 under Rule 126 of the CGST Rules, 2017. However, no fixed formula which fits all the cases of profiteering can be set while determining such a Methodology and Procedure as the facts of each case are different. In one real estate project, 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, 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 from the other project and hence the amount of benefit of additional ITC to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... B 110/- 3. GST@ 18% C=B*18% 19.80/- 4. Selling price (including GST) D=B+C 129.80/- 5. GST Rate E 18% 5% 6. Denial of ITC of 9.64% as per table- B above F=B*9.64% 10.60/- 7. Commensurate Base price (post Rate reduction) (Excluding GST) G=B+F 120.60/- 8. Commensurate Selling price (post Rate reduction) (including GST) H=105% of G 126.63/- 9. Selling price (including GST) as per Menu Price List I 130.20/- 10. The excess amount charged or Profiteering ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Advisor to the Chief Minister, Punjab as well as the Chief Economic Advisor raised the issue of the requirement of having a mechanism to compute profiteering with proper checks and balances. However, the issues raised by the above officers are incorrect as the methodology to compute the profiteering is itself contained in Section 171 of the CGST Act, 2017 as has been explained above. The Respondent has also pointed out that the Malaysian Government has introduced the Price Control and Anti-Profiteering (Mechanism To Determine Unreasonably High Profits for Goods) Regulations, 2018, and under the said Regulations, any profit earned over and above the determined Net Profit Margin was considered as an unreasonably high profit rendering the supplier liable for penal action under the law. The anti-profiteering measures in Australia revolved around the Net Dollar Margin Rule serving as the fundamental principle for the determination of price variances and changes as its guideline. In this regard, it would be appropriate to mention that the above Act has been repealed by Malaysia as it was not found to be working properly. Moreover, this Act was promulgated to control prices after ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tigation from 15.11.2017 to 30.06.2019 has been rightly taken by the DGAP for computation of the profiteered amount. 45. The Respondent has also claimed that the DGAP while calculating the profiteered amount has erroneously added a 5% additional amount on account of GST which has been collected from the customers and deposited with the Government of India with the monthly GST returns. This contention of the Respondent is not correct because the provisions of Section 171 (1) and (2) of the CGST Act, 2017 require that the benefit of reduction in the tax rate is to be passed on to the recipients/ customers by way of commensurate reduction in price, which includes both the base price and the tax. The Respondent has not only collected excess base prices from the customers which they were not required to pay due to the reduction in the rate of tax but he has also compelled them to pay additional GST on these excess base prices which they should not have paid. By doing so, the Respondent has defeated the very objective of both the Central as well as the State Government which aimed to provide the benefit of rate reduction to the general public. The Respondent was legally not required t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve and contrary to the delegatus non potest delegare principle is not tenable. Further the Respondent has placed reliance on the cases of Hamdard Dawakhana and Anr. v. Union of India and Ors. AIR 1960 SC-554, District Collector, Chittoor v Chittoor Groundnut Traders Association AIR 1989 SC 989 and the judgement passed by Hon ble High Court of Kerala dated 03.09.2014 in writ Appeal No. 917 of 2014 filed by Ultratech Cement Ltd . In this regard, it is observed that the facts of the above cases are different from the present case, therefore, they are not applicable in the instant case. 47. Based on the above facts as per the provisions of Sec 171 (1) read with Rule 133 (1) the profiteered amount is determined as ₹ 6,85,531/- as has been computed in Annexure-15 of the DGAP s Report dated 27.12.2019. Accordingly, the Respondent is directed to reduce his prices commensurately in terms of Rule 133 (3) (a) of the above Rules. Further, since the recipients of the benefit, as determined, are not identifiable, the Respondent is directed to deposit an amount of ₹ 6,85,531/- in two equal parts of ₹ 3,42,766/- each in the Central Consumer Welfare Fund and the Maharash ..... X X X X Extracts X X X X X X X X Extracts X X X X
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