Goods and Services Tax Appellate Tribunal, Principal Bench, New Delhi, Anti-Profiteering Division · GST · AKHB case note
Director General of Anti-Profiteering v. Ireo Pvt. Ltd. (City Central, Managed Service Apartment and Skyon)
NAPA/73/PB/2025
No neutral or reporter citation printed in the identified official order. ·
Final reasoned merits determination accepting a project-specific no-profiteering conclusion and dropping proceedings.
Ireo Pvt. Ltd., confined to the three identified projects and the examined benefit comparisons.
01 · Facts of the case and issues
Following a wider project investigation directed by NAA Order 14/2019 dated 21 October 2019, DGAP examined Skyon, Ireo City Central and Managed Service Apartment. Its initial report was dated 15 December 2021. A reinvestigation followed the Delhi High Court’s 29 January 2024 Reckitt Benckiser decision, and a revised report dated 20 August 2025 was considered at the 9 October 2025 hearing. The comparison used April 2012–June 2017 and July 2017–March 2024 periods. The source records that the investigation was directed by CCI and that no direct complaint against these projects had been received.
Source: Paras 1–5 and 8; physical pp.2–8 and 16.
02 · Discussion and reasoning of the Hon’ble Court
For Skyon, the order compares pre-GST credit of ₹31,64,28,447 with net post-GST credit of ₹73,93,179 against purchase values of ₹5,13,87,58,946 and ₹1,14,00,46,423 respectively. The ratios fall from 6.16% to 0.65%. The post-GST net amount reflects reversals and transitional credit, rather than gross GST credit alone. The respondent submitted that construction had been completed before GST; the same paragraph records an occupation certificate dated 14 September 2017. Those statements should not be conflated into a finding that the certificate predated GST.
City Central and Managed Service Apartment were treated together because of the common commercial licence and contractor. Their pre-GST credit of ₹7,16,92,557 and net post-GST credit of ₹9,58,827 were compared with purchases of ₹1,17,59,37,173 and ₹26,08,84,580, producing 6.10% and 0.37%. The source expressly records that exact verification of project costs against audited accounts was not feasible and describes area-based apportionment.
The Tribunal accepted the project-specific ITC-to-construction-cost approach and the conclusion that there was no additional benefit to pass on. Its use of this method does not prescribe one universal formula for every real-estate project.
Source: Paras 6.1–6.9, 7.1–7.6 and 9; physical pp. 8–16.
03 · Judicial decision and operative relief
The Tribunal concluded that no post-GST tax-rate or ITC benefit accrued in respect of Skyon, Ireo City Central and Managed Service Apartment. It held Section 171 inapplicable on these project facts and dropped the proceedings. No monetary award, interest or penalty is directed. The final order was signed, dated and pronounced on 28 October 2025.
Source: Paras 10–12, physical pp. 16–17; summary physical p. 2.
04 · In favour of
Final reasoned no-profiteering determination; proceedings dropped after evaluation of the investigation, rather than a hearing adjournment or interim direction.
Source: Operative paras 10–12.
05 · AKHB REVIEW POINT
AKHB analysis: Reconcile gross credit, reversals and transitional credit before comparing tax benefits. A fall in the properly adjusted ratio supports this order’s no-benefit finding, but should not be applied to another project without its own evidence. Separate project periods, areas, completion status and accounting allocation.
The Skyon computation is ₹4,40,97,274 −₹1,40,86,992 +₹1,42,38,477 −₹3,68,55,580 =₹73,93,179. The combined City Central/MSA computation is ₹6,80,44,335 −₹3,39,60,955 +₹51,48,323 +₹73,71,544 −₹4,56,44,420 =₹9,58,827. These reproduce the order’s arithmetic; they are not an audit of the underlying books. The express project-cost verification limitation deserves attention when comparing the decision with cases supported by directly traceable project accounts.
Do not merge this order with NAPA 51/PB/2025, decided the same day for Gurgaon Hills and Grand Hyatt. Nor does the introductory reference to Ireo Grace Realtech establish that it is legally identical to the present captioned respondent.
Source: AKHB analysis of paras 6–10; physical pp.8–17.
Source and verification
Complete official source read; identity, calculations and operative pages visually checked. · Individual hosted copy of the original judgment
Complete 17-page official order, including administrative summary. Underlying project accounts, returns, credit reversals and DGAP working papers were not independently obtained.
Source checked 2026-10-17. Paragraph references follow the identified official judgment; PDF-page references follow that source file. The court’s printed paragraph numbers may differ from commercial reporting.
Compared with 202 published identities and source hashes and 199 nonempty normalized source texts; three scanned baseline sources cannot support text-hash comparison.
The two Ireo orders of 28 October 2025 are separate cases involving different projects; do not merge on party/date alone.
Statutory scope
Historical source-based explanation of the law and notifications applied in this order; not a current statutory consolidation.
Later treatment and present applicability
Bounded exact-case, party and appeal/recall searches on 17 October 2026 identified no later primary order affecting this decision. This is not exhaustive docket clearance or proof that no appeal exists.
Additional identified sources
AI disclosure & professional disclaimer
AI-assisted research checked against the identified primary source. Extraction, interpretation or omission errors remain possible. Source review does not mean independent approval by a practising professional. Verify every material statement against the complete original judgment.
General research information only; not legal or tax advice, a certified judgment or a substitute for the full order. Applicability depends on the facts, tax period, statutory version and jurisdiction. Subsequent treatment is unverified unless the note expressly identifies the sources checked. Downloading does not create a professional engagement. Obtain case-specific advice before reliance.