Goods and Services Tax Appellate Tribunal, Principal Bench, New Delhi, Anti-Profiteering Division · GST · AKHB case note
Director General of Anti-Profiteering v. Raja Housing Limited
NAPA/165/PB/2025
No neutral or reporter citation printed in the identified official order. ·
Final substantive anti-profiteering closure after consideration of the state screening record and hearing the complainant; not a remand and not an adjudication cancelling the separate invoice-related DRC-01 demand.
Raja Housing Limited, confined to the anti-profiteering allegation concerning Raja Ritz Avenue Phase-I. No independent cancellation of invoice-related enforcement is ordered.
01 · Facts of the case and issues
A purchaser in Raja Ritz Avenue Phase-I complained that the developer’s receipt did not separately reflect the GST component paid. The Karnataka State Screening Committee considered investigation, enforcement and audit material. The Tribunal recorded that the project commenced before 1 April 2019 and that the developer continued under the old tax scheme, described in the source as 12% with land exemption and ITC. The record said customers were charged 5%, while the developer bore the differential tax burden. These are findings recited from the case record, not a general statement of current real-estate GST rates.
Sale deeds, payment vouchers, customer-wise ledgers and audit material were examined. The source also records separate invoice-related enforcement proceedings and DRC-01 dated 24 February 2025 referring to ₹10,35,80,038, and total tax discharged of ₹17,01,94,057. These amounts are not anti-profiteering awards made by this judgment.
Source: Physical p. 3, unnumbered factual paragraphs; p. 4, first three paragraphs.
02 · Discussion and reasoning of the Hon’ble Court
The issue was whether this receipt/invoicing grievance and the investigated financial record established profiteering. The Tribunal examined the Karnataka screening minutes and the underlying findings described in them. The record found no substantiated tax evasion on the issue investigated and showed the consideration, collections and tax discharge in the financial material.
The original complainant was invited to object to the screening findings, filed no written objections, and was nevertheless heard virtually. The Tribunal found no illegality or irregularity in the screening minutes and concluded that no profiteering had occurred on this record. The conclusion rests on the facts and verification recited in this case; it does not license defective invoicing.
Source: Physical p. 3, screening and audit discussion; p. 4, paragraphs beginning “Considering the statement”, “In that view” and “Today”.
03 · Judicial decision and operative relief
The Tribunal found no profiteering, dropped the allegation against Raja Housing Limited and closed the proceedings. The signed reasoned order is dated 8 January 2026. The summary/signature page and digital signature carry 9 January 2026; the judgment is indexed by its stated decision date of 8 January.
The operative text does not order a buyer refund, Consumer Welfare Fund deposit, interest or penalty. Nor does it set aside, quantify relief against or finally adjudicate the separate DRC-01 invoice-enforcement matter described in the background.
Source: Physical p. 4, final two substantive paragraphs and date line; p. 1, date of order; p. 2, summary date; p. 4 digital signature.
04 · In favour of
Final case-specific no-profiteering determination accepting the state screening record after hearing the original complainant. The administrative “Closure Report” and “Confirmed” labels must be read with the reasoned operative conclusion.
Source: Physical pp. 1–2 summary and p. 4 operative conclusion.
05 · AKHB REVIEW POINT
AKHB analysis: Reconcile the contract/sale deed, tax collected from the purchaser, tax actually discharged, rate-option records and customer-wise ledgers before treating an invoice complaint as an anti-profiteering claim. Keep invoicing compliance and the section 171 allegation analytically distinct. A favourable anti-profiteering closure does not establish that all separate tax or invoice proceedings have been cancelled.
Do not extrapolate the recorded 5% collection and 12% discharge into a rate prescription for other projects or periods. Establish the project’s applicable option, notification conditions and evidence independently. This short decision gives a fact-specific closure, not a general exemption for developers or permission to omit GST particulars from invoices.
The source’s DRC-01 amount and tax-paid amount have different functions. Neither is the relief awarded by this order. The original order contains no numbered paragraphs, so physical-page and opening-phrase references are used.
Source: AKHB source-based analysis; physical pp. 3–4. Not an additional judicial holding.
Source and verification
Complete four-page official PDF. All extracted text read and all four pages visually checked; original bytes retained. · Individual hosted copy of the original judgment
Original GSTAT anti-profiteering order and its administrative summary only. Underlying audit reports, invoices, screening minutes and separate DRC-01 record 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.
All four official source pages visually inspected.
195 original-byte hashes and identities checked; 192 nonempty normalized full texts checked.
No identical hash/text or matching case identity found. Three scanned baseline originals are excluded from automated text-equality evidence.
Statutory scope
References describe the order and its historical record. No current statutory consolidation or universal rate conclusion is certified.
Later treatment and present applicability
Bounded searches on 17 October 2026 for the exact party/case/date and recall/stay terms found no identified later primary order affecting this NAPA decision. This is not exhaustive appellate-docket clearance or proof that no appeal exists. A Supreme Court cause-list hit for Raja Housing v. Kota Naveen Kumar, SLP(C) 5359/2022, is a different older case and was not treated as an appeal from this 2026 order.
Additional identified sources
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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.
