This presentation covers the provisions related to assessments, audit, penalties, prosectuion and show cause notice provisions under GST laws updated upto 31-05-2017

1. Assessments & Audit under
GST
Amit Mundhra, FCA
Mobile : 9829010172
Email : amit.mundhra@gmail.com

2. Meaning of Assessment - Sec 2(11)
 “Assessment” means determination of tax liability under this Act and includes self
assessment, re assessment, provisional assessment, summary assessment and
best judgment assessment.
 Self assessment
 Re-assessment
 Provisional assessment
 Summary assessment
 Best judgment assessment

3. Chapter 12 - Assessment
 Self assessment (Sec 59)
 Provisional Assessment (Sec 60)
 Scrutiny of tax returns filed by registered taxable person (Sec 61)
 Assessment of non filers of returns (Sec 62)
 Assessment of unregistered persons (Sec 63)
 Summary Assessment in certain special cases (Sec 64)

4. Self Assessment – Sec 59
 Every registered person shall himself assess the taxes
payable under this act and furnish a return for each tax period

5. Provisional Assessment : Sec 60
 This provision can be used by taxable person in following situations [sec 60(1)
 When value of supply cannot be determined i.e. there is difficulty in
 Ascertaining transaction value to be adopted
 What to include what to exclude etc.
 When tax rate applicable cannot be determined i.e. there is difficulty in
 Ascertaining classification
 Any exemption matter
 Similar provisions are presently there in Rule 6(4) of Service Tax Rules.

6. Procedure of Provisional Assessment
As per Draft Assessment Rules following procedure is specified
 Form GST ASMT-01 - File application for provisional assessment
 Form GST ASMT-02 - Proper officer will issue notice fixing PH or additional
information
 Form GST ASMT-03 - Reply to be filed by applicant
 Form GST ASMT-04 - Officer will issue order either rejecting with grounds or
allowing payment of tax on provisional basis within 90 days from the date of
receipt of application
 Form GST ASMT-05 - Bond to be executed with security not exceeding 25% of
amount covered under bond

7. Procedure of Provisional Assessment
contd..
 Form GST ASMT-06 - Proper officer will again call for information for finalization
of assessment.
 Form GST ASMT-07 - Final assessment order to be passed within 6 months from
the date of communication of provisional assessment order.
 Joint Commission or Additional Commissioner can extend this period by 6 more
months and Commissioner can extend it upto 4 years.
 Form GST ASMT-08 - Applicant will file application for release of security
 Form GST ASMT-09 - After ensuring the balance payment if any, final order to be
issued within 7 working days of receiving release application.
 Refund if any shall be granted u/s 54 subject to principle of unjust enrichment

8. Section 61 : Scrutiny of Returns
Process:
 Form GST ASMT-10 - Notice for selection of scrutiny to be communicated with
quantified amount of tax, interest or any other amount payable.
 Maximum time allowable for response is 15 days
 Form GST ASMT-11 - Person can either accept the discrepancy or furnish
explanation.
 Form GST ASMT-12 - If explanation found acceptable then intimation will be
provided.

9. Section 61 : Scrutiny of Returns contd..
Section 61(3):
 If satisfactory explanation is not submitted with 30 days or such extended
period..
 Or if discrepancy is accepted but corrective action is not taken in the return
of the month in which such discrepancy is accepted
 Proper officer may initiate appropriate actions under
 Section 65 - audit
 Section 66 - special audit
 Section 67 – inspection
 Section 73 or 74 - Adjudication

10. Section 62 : Assessment of Non Filers
 If regular returns u/s 39 or 45 not filed even after notice u/s 46, this section can be
invoked
 Best judgment assessment can be completed without giving notice
 Based on material available or gathered, no opportunity of hearing.
 Order can be passed within 5 years from the due date of Annual return of the
respective financial year [Generally it will come to 69 months]
 Assessment order to be issued in Form ASMT-13
 If valid return is filed within 30 days of service of order, this assessment will be
deemed to be withdrawn. No provision of condonation of delay.

11. Section 63 : Assessment of unregistered
person
This section can be invoked if;
 A person who fails to obtain registration even though liable or
 A person whose registration is cancelled u/s 29(2) but is liable to pay tax
 Order can be passed within 5 years from the due date of Annual return of the
respective financial year [Generally it will come to 69 months]
 Opportunity of being heard should be provided in this case
 Notice in Form ASMT-14 containing the grounds on which assessment is proposed
to be made. Time given for response is 15 days.

12. Section 64 : Summary Assessment in
special cases
 This section can be invoked if proper officer has
 Evidence that there is a tax liability
 Prior permission from Additional Commissioner or Joint Commissioner
 Sufficient grounds that any delay in assessment will be against the interest of
revenue.
 No opportunity of being heard.
 Later if person files application within 30 days of receipt of order or proper
officer can suo motto withdraw such order.
 After such withdrawal procedure of section 73 and 74 to follow.

13. Section 65 : Audit by departmental
authorities
 Commissioner will authorize the persons to conduct audit
 Audit may be conducted at the place of business of assesse
 Notice in form GST ADT-01 to be issued for submission of documents
allowing response time not less than 15 days
 Audit to be completed within 3 months from the date of commencement.
Period can be extended by 6 months by commissioner
 What is date of commencement?
 Date on which records called for are made available or
 Date of actual start of audit at business place whichever is later

14. Section 65 : Audit by departmental
authorities contd…
 On conclusion, within 30 days the officer shall inform the following points
to the assesse in for GST ADT-02
 Findings of audit
 Rights and obligations of the assesse
 The reason of such findings
 As per rules, audit will be in multiple of financial years only.
 If audit results in non payment, short payment, erroneous refund, wrong
availment or utilization of ITC then section 73 and 74 initiated

15. Section 66 : Special Audit
 Assistant commissioner with prior approval of commissioner can authorize
special audit in complex cases where in view of him
 Value has not been declared correctly
 The credit availed is not within normal limits
 Special audit may be ordered by nominated CA or ICWA.
 Report to be submitted with 90 days. Further extension of 90 days can be
allowed
 Opportunity of being heard to be provided to assesse before authorizing
special audit.

16. Penalties and Prosecution
provisions under GST Law
Amit Mundhra, FCA
Mobile : 9829010172
Email : amit.mundhra@gmail.com

17. Section 73 : Determination of tax
 When proper officer finds that
 Tax not paid
 Tax short paid
 Tax erroneously refunded
 Input tax wrongly availed
 Input tax wrongly utilized
 For reason other than fraud, willful misstatement or suppression of facts to
evade tax
 May issue SCN to such person

18. Section 73 …
Time Limit to issue notice – Sec 73(2)
 At least 3 months prior to time limit of issuance or order
Time Limit to issue of order – Sec 73(10)
 Proper officer shall issue the order within 3 years from the due date of furnishing
the Annual Return for the financial year to which such notice relates
 Within 3 years from the date of issue of erroneous refund
Further service of an statement will be deemed to be SCN – Sec 73 (3) & (4)
 Officer may deliver statement relating to other periods
 Grounds relied upon must be same, then such statement will be deemed to be
SCN.

19. Section 73 …
Payment of Tax + Interest before service of SCN – Sec 73(5)
 Person may pay Tax + Interest on own ascertainment before service of SCN and
intimate the officer about such payment in writing
Officer will not issue SCN in respect of tax such paid – Sec 73(6)
 If payment of tax + interest made officer will not issue SCN
Issue of SCN for the balance amount if any – Sec 73(7)
 If amount paid as such falls short as per calculation of officer, he may issue SCN
for the balance amount.

20. Section 73 …
Payment of Tax + Interest within 30 days of issue of SCN – Sec 73(8)
 No penalty will be levied and notice deemed to be concluded
Issue of Adjudication order – Sec 73(9)
 After considering representation of assesse, order will be issued levying Tax +
Interest + Penalty (10% of Tax or Rs. 10000/- whichever is higher)
Compulsory Penalty – Sec 73(11)
 If during this proceedings it is found that self assessment tax or tax collected is not
paid within 30 days of due date penalty u/s 73(9) will be compulsorily levied.

21. Section 74 : Determination of tax
 When proper officer finds that – sec 74 (1)
 Tax not paid
 Tax short paid
 Tax erroneously refunded
 Input tax wrongly availed
 Input tax wrongly utilized
 For reason of fraud, willful misstatement or suppression of facts to evade
tax.
 May issue SCN to such person

22. Section 74 …
Time Limit to issue notice – Sec 74(2)
 At least 6 months prior to time limit of issuance or order
Time Limit to issue of order – Sec 74(10)
 Proper officer shall issue the order within 5 years from the due date of furnishing
the Annual Return for the financial year to which such notice relates
 Within 5 years from the date of issue of erroneous refund
Further service of an statement will be deemed to be SCN – Sec 74 (3) & (4)
 Officer may deliver statement relating to other periods
 Grounds relied upon must be same, then such statement will be deemed to be
SCN.

23. Section 74 …
Payment of Tax + Interest + Penalty before service of SCN – Sec 74(5)
 Person may pay Tax + Interest + Penalty (15 % of Tax) on own ascertainment
before service of SCN and intimate the officer about such payment in writing
Officer will not issue SCN in respect of tax such paid – Sec 74(6)
 If payment of tax + interest + penalty made officer will not issue SCN
Issue of SCN for the balance amount if any – Sec 74(7)
 If amount paid as such falls short as per calculation of officer, he may issue SCN
for the balance amount.

24. Section 74 …
Payment of Tax + Interest + penalty within 30 days of issue of SCN – Sec 74(8)
 If assesse pays Tax + Interest + Penalty (25 % of Tax) within 30 days of issue of
SCN then notice deemed to be concluded
Issue of Adjudication order – Sec 74(9)
 After considering representation of assesse, order will be issued levying Tax +
Interest + Penalty (100% of Tax)
Payment of Tax + Interest + penalty within 30 days of service of order – Sec
74(11)
 If assesse pays Tax + Interest + Penalty (50 % of Tax) within 30 days of service
of order then all proceedings of said notice deemed to be concluded

25. Definition of “Suppression” – Sec 74
For the purpose of this Act, the expression “Suppression” shall mean
 Non declaration of facts or information which a taxable person is required to
declare in the return, statement, report or any other document furnished under this
Act or the rules made thereunder
Or
 Failure to furnish any information on being asked for in writing by proper officer

26. Chapter 19 : Offences and Penalties
Offences and
Penalties
Specific defaults
(section 122 – 124)
General Defaults
(Section 125-128)
Detention and
confiscation
(Section 129-130)
Prosecution and
Compounding
(Section 131 to
138)

27. Section 122 : Penalty for Specific Defaults
Section 122
Penalty for
procedural
defaults [section
122(1)]
Penalty for Tax
defaults [section
122(2)]
Penalty for other
defaults [section
122(3)

28. Section 122(1) : Specific Defaults
S.n
.
Category of default Nature of default
1 Invoice - Supply without invoice or with false invoice
- Issue of invoice without supplying the goods or
services
- Issues invoice with GSTIN of other person
2 Payment of Tax, TDS, TCS
and Refund
- Collects amount as tax but fails to pay beyond 3
months from due date
- Fails to deduct TDS, Short deduction, fails to pay
deducted TDS
- Fails to collect TCS, short collection, fails to pay the
collected TCS
- Fraudulently obtains refund
3 ITC - Takes or utilizes ITC without actual receipt of goods
or services
- Takes or distributes ITC as ISD in contravention of
section 20

29. Section 122(1) : Specific Defaults
S.n. Category of default Nature of default
4 Accounting Records - Falsifies, substitutes, produces fake records, furnishes
false information or return with intention to evade the tax
- Fails to keep, maintain or retain books in accordance with
provisions of law.
5 Turnover - Suppression of turnover
6 Registration - Is liable for taking registration but does not take
- Furnishes false information at time of registration
7 Transportation - Transports any taxable goods without documents

30. Section 122(1) : Specific Defaults
S.n. Category of default Nature of default
8 Others - Obstructs or prevents any officer from performing his
duties
- Fails to furnish or furnish false information or documents
called for
- Supplies, transports or stores goods which he has reason
to believe are liable for confiscation.
- Tampers with or destroys material evidence
- Dispose of or tampers with any goods which have been
detained, seized or attached.

31. Section 122(1) : Specific Defaults
Amount of Penalty under this section is
Rs. 10000/-
Or
100% of amount of tax involved
Whichever is higher

32. Section 122(2) : Penalty for tax defaults
S.N. Nature of Default Reason Quantum of penalty
1 Supplies goods or services
on which
- Tax not paid
- Tax short paid
- Tax erroneously
refunded
- ITC wrongly availed
- ITC Wrongly utilised
Not by way of fraud, willful
misstatement, suppression of
facts
Higher of
Rs. 10000/-
or
10% of tax amount involved
2 By way of fraud, willful
misstatement, suppression of
facts
Higher of
Rs. 10000/-
Or
100% of tax amount involved

33. Section 122(2) : Relation with section 73
and 74
 Section 73 covers the cases where fraud, willful misstatement or suppression is
not involved
 Manner of levy of penalty is as below
Tax and Interest paid Amount of Penalty
Before service of SCN No Penalty
Within 30 days after the issuance of SCN No penalty
In any other case Higher of 10% or tax involved and Rs.
10000/-

34. Section 122(2) : Relation with section 73
and 74
 Section 74 covers the cases where fraud, willful misstatement and suppression is
involved
 Quantum of penalty is as below
Tax, Interest and Penalty paid Amount of Penalty
Before service of SCN 15% of tax amount
Within 30 days after the issuance of
SCN
25% of tax amount
Within 30 days from the
communication of adjudication order
50% of tax amount
In any other case 100% of the tax amount

35. Section 122(2) : Relation with section 73
and 74
 Whether penalty provisions u/s 73 and 74 are independent of penalty
provisions under section 122(2)?
 In my view they are independent provisions. There is no linkage provided in the
law between these two sections
 Can both these penalties be levied simultaneously?
 The Answer is No, in section 75(13) there is a specific provision which says the if
penalty u/s 73 and 74 is imposed, no penalty under this Act will be imposed on the
same default

36. Section 122(3) : Penalty on other defaults
 Penalty upto Rs. 25000/- can be levied on any person who commits following
offences
 Aids or abets any of the offences in section 122(1)
 Acquires possession of or in any way concerns himself in transporting, removing,
depositing, keeping, concealing, supplying or purchasing or in any manner deals with the
goods which he knows or have reason to believe are liable for confiscation.
 Receives or in any way concerned with the supply of services which he knows that are in
contravention of the act.
 Fails to appear before authority
 Fails to issue invoice or fails to account for an invoice.

37. Secton 123 – 124 : Penalty on failure to
furnish information or statistics
Failure to furnish information
return as specified in section
150 – Section 123
Rs. 100/- per day but maximum Rs. 5000/-
Failure to furnish statistics as
given in section 151 – Section
124
Rs. 100/- per day but maximum Rs. 5000/-

38. Section 125: General Penalty
 Penalty upto Rs. 25000/- can be levied
 On any contravention of the provisions of this act for which no specific penalty is
given anywhere in the Act

39. Section 126 : General Disciplines relating
to penalty
 This is a welcome section which specifies the general procedure to be followed
by proper officer in penalty proceedings.
 No penalty for minor breach (if amount of tax involved is less than Rs. 5000/-)
 No penalty for minor breaches of procedural requirements, omission or mistake which can be
easily rectifiable and are made without fraudulent intent or gross negligence.
 Levy of penalty will depend on facts and circumstances of each case and shall be
commensurate with degree and severity of the breach
 Opportunity of being heard should be provided.
 In order imposing penalty the proper officer should specify
 Nature of breach
 Applicable law or regulation in which penalty is specified
 Voluntary disclosure of any breach by a person may be considered as mitigating factor while
imposing penalty.

40. Section 126(6) : Welcome Mat Removed
 This provision says;
 The provisions of this section shall not apply in such cases where the penalty
specified under this Act is either a fixed sum or expressed as fixed percentage.
 In almost all the cases under this act, penalty is either payable as fixed
sum or fixed percentage. Barring 2-3 situations.
 So this section is a Ghost section for all practical purposes.

41. Section 129: Detention, seizure and release of
goods and conveyance in transit
 When any person – Section 129(1)
 transports any goods or
 stores any goods while they are in transit
 in contravention of the provisions of this law

42. Section 129: Detention, seizure and release of
goods and conveyance in transit
S.N. Particulars Amount of Payment to be made
1 Where owner of goods comes forward Taxable Goods :
Tax + Penalty equal to the amount of Tax
Exempted Goods
2% of value of goods or Rs. 25000/-
whichever is less.
2 Where owner of goods does not comes
forward
Taxable Goods :
Tax + Penalty equal to the 50% of value of
goods (value of goods = value – tax paid)
Exempted Goods
Lower of 5% of value of goods or Rs. 25000/-

43. Procedure u/s 129
 Service the order of detention on person transporting the goods – section
129(1)
 Goods may be provisionally released on furnishing of bond and security –
section 129(2) read with section 67(6)
 Notice for payment of tax and penalty to be issued – Sec 129(3)
 Provide opportunity of being heard – Sec 129(4)
 Pass order for payment of tax and penalty – Sec 129(3)

44. Procedure u/s 129
 Payment to be made within 7 days of such detention or seizure otherwise
proceeding u/s 130 be initiated - Sec 129(6)
 If goods are perishable then this period of 7 days may be reduced by proper officer
 Goods can also be released upon furnishing of security equivalent to the amount
payable under this section.

45. Section 130 : Confiscation of goods and
conveyance
 What is difference between confiscation and detention?
 In detention the ownership of goods lies with the owner
 In confiscation the ownership of goods passes to government

46. Section 130 : Cases where goods or
conveyance are liable for confiscation
 If any person
 Supplies o receives any goods in contravention of the provisions of this act and rules
with intent to evade payment of tax
 Does not account for any goods on which he is liable to pay tax under this act
 Supplies any goods liable to tax under this act without applied for registration
 Contravenes the provisions of this act and rules with intent to evade tax
 Uses any conveyance as a means of transport in contravention to the provisions of act
and rules unless owner of such conveyance proves that it was used as such without his
knowledge.
 In above cases such goods or conveyance shall be liable for confiscation and
penalty u/s 122 will be levied.

47. Section 130(2) : Payment of fine in lieu of
confiscation (Redemption Fine)
 Option to be provided to owner of the goods, either allow confiscation of goods or
to pay fine in lieu of confiscation
 Proper officer can levy the fine at his discretion between the following range
Maximum Fine Minimum Fine
Market value of goods confiscated less
tax chargeable
Amount of penalty leviable u/s 129(1) i.e.

48. Section 130 (2) : Payment of fine in lieu of
confiscation (Redemption Fine)
 If the conveyance used for carriage for goods or passengers for hire then owner of
the conveyance shall also be given option to pay redemption fine
 equal to the amount of tax payable on goods being transported
 Total amount to be paid if option exercised – Sec 130(3)
 Tax on goods
 Penalty (u/s 122 which can be equal to amount of tax)
 Other Charges
 Redemption Fine

49. Section 130 : Confiscation
If option not exercised –
 Proper officer will pass order of confiscation after granting opportunity of being
heard – sec 130(4)
 Title of such goods will vest with government – section 130(5)
 Proper officer will take possession of goods – section 130(6)
 Proper officer may further allow time of 3 months to pay redemption fine otherwise
goods may be disposed off – section 130(7)

50. Section 74, 129 & 130 : Effect on input tax
credit
 Section 17(5)(i) says input tax credit is not available
 On any tax paid in accordance with the provisions of section 74, 129 and 130
 Also in Invoice Rules, rule 8(3) says
 An invoice or debit note issued in pursuance of any tax payable in accordance with
section 74, 129 or 130 shall prominently contain the words “INPUT TAX CREDIT NOT
ADMISSIBLE”.
 What does this mean?

51. Section 132 : Prosecution
 Prosecution can be launched in following offences
S.n. Nature of default
(a) Supply without invoice with intention to evade tax
(b) Issue of invoice without supplying the goods or services leading to wrong
availment or utilization of input tax credit.
(c) Avails or utilizes ITC without actual receipt of goods or services using invoice
referred to in (b) above
(d) Collects amount as tax but fails to pay beyond 3 months from due date
(e) Evades tax, fraudulently avails ITC or fraudulently avails refund

52. Section 132 : Prosecution
S.n. Nature of default
(f) Falsifies, substitutes, produces fake records, furnishes false information or return with intention to
evade the tax
(g) Obstructs or prevents any officer from performing his duties
(h) Acquires possession, or concerns himself in transporting, removing, depositing, keeping,
concealing, supplying or purchasing or dealing in goods which he has reason to believe are liable
for confiscation.
(i) Receives any supply or in any way concerned with such supply which he knows that is in
contravention of this Act.
(j) Tampers with or destroys material evidence
(k) Fails to furnish or furnish false information or documents called for
(l) Attempts to commit or abets the commission of any of the above offences.

53. Section 132 : Punishment
Amount of TAX involved in
contravention
Fine Imprisonment Status
Offence in clauses (a), (b), (c) and (d)
and amount involved is exceeding Rs.
5 Crores
Yes Upto 5 years Cognizable and
non bailable
Other offences where amount involved
is exceeding Rs. 5 Crores
Yes Upto 5 Years Non cognizable
and bailable
Rs. 2 crore to Rs. 5 Crores Yes Upto 3 Years Non cognizable
and bailable
Rs. 1 Crore to Rs. 2 Crores Yes Upto 1 year Non congnizable
and bailable
If cases of defaults u/s clase (f), (g) or
(j)
Yes Upto 6 Months Non cognizable
and bailable

54. Meaning of Cognizable & Bailable
What is cognizable offence?
 An offence when the police can arrest the person without warrant
What is non cognizable offence?
 An offence when the police cannot arrest the person without warrant
What is bailable offence?
 An offence where one can obtain bail as a matter of right. Bail cannot be denied
What is non bailable offence?
 An offence where bail cannot be claimed as a right. It is upto the discretion of the court
to grant bail or not.

55. Section 132 : Prosecution
If a person is again convicted of an offence under this section – Sec 132(2)
 Punishment for second and for every subsequent offence imprisonment upto 5
years
Minimum Punishment in case of tax evasion – Sec 132(3)
 Minimum punishment of 6 months unless reasons to the contrary recorded by the
court.
Prosecution only on approval by Commissioner – Sec 132(6)

56. Section 138 : Compounding of Offence
 Compounding can be done either before or after the institution of prosecution –
Sec 138(1)
 Compounding can be allowed by Commissioner
 Amount of compounding - Sec 138(2)
 Minimum : Rs. 10000/- or 50% of tax involved whichever is higher
 Maximum : Rs. 30000/- or 150% of tax involved whichever is higher
 On compounding, no further proceeding shall be initiated under this Act.

57. Section 138 : Compounding of Offence
Following persons cannot go for compounding – Sec 138(1)
 Person who was allowed to compound once in respect of offences under clause
(a) to (f) and clause (l) of section 132(1)
 In case of other offences of section 132(1), where a person was allowed to
compound earlier in respect of taxable supplies exceeding Rs. 1 crore.
 Person who is accused of committing an offence under this act which is also an
offence under any other law.
 A person who has been convicted under this law by court.
 A person who is accused of committing offence under clause (g), (j) or (k) of
section 132(1)

58. Two Schemes of GST Law
 Suppose an evasion or default is detected by proper officer under CGST Law.
 In most of the cases, if default is there in CGST Law, there will be automatic default in
SGST Law
 As both Laws are separate laws, penalty proceedings are also separate.
 So wherever in the GST if there is fixed amount of penalty is leviable which is not linked to
tax amount, both penalties will be payable. Under CGST and under SGST.
 Buy One Get One Free *conditions apply”
 And if unfortunately evasion of IGST is also detected
 Then separate penalties for
 CGST - SGST and IGST
 Buy One Get Two Free *conditions apply”

59. Penalties : Important point to keep in Mind
 See Section 6 of CGST Act
 Who is the proper officer in CGST Act will also be proper officer in SGST Act
 Proper officer issuing order under CGST Act will also issue order under SGST Act
 Similar provisions are there in SGST Act
 So here important point to keep in mind is that we are not dealing with 1 GST Law.
We are dealing with 3 Laws.
 CGST Law
 SGST Law
 IGST Law
 Penalty and prosecution provisions are independent in each of such laws

60. Penalties : Important point to keep in Mind
 See section 20 of IGST Law
 Provisions relating to CGST shall mutatis mutandis apply in case of IGST
 Forth proviso says “in cases where penalty is leviable under CGST Act and SGST Act or
UTGST Act, penalty leviable under this Act shall be sum total of the said penalties

61. Two Schemes of GST Law
What will happen in case of Prosecution?
 Whether there will be single term sentence?
 Or sentence will be in addition (1+1+1)?

62. Section 132 : Prosecution
Meaning of “Tax” under this section – Explanation to section 132
 “Tax” shall include the amount of
 tax evaded,
 input tax credit wrongly availed or utilised
 Refund wrongly taken
 Under the provisions of CGST Act, SGST Act, IGST Act and UTGST Act and cess
levied under compensation to states act.
 So considering this provision, in my view prosecution can only be once.

63. Thank You !
Amit Mundhra, FCA
KARNANI & CO.
134, Girnar Colony South,
Gandhi Path, Vaishali Nagar, Jaipur
Mobile : 9829010172
Email : amit.mundhra@gmail.com
Web : www.karnanica.com