India's Anti-Profiteering Void: Consumer Protection Challenges after the GST Rate Cuts
The authors are Ekansh Jain and Eshita Dhawan, 4th year student at Rajiv Gandhi National University of Law, Patiala
Keywords: GST, NAA, CGST, GSTAT, Anti-Profiteering
INTRODUCTION
Goods and Services Tax (“GST”) 2.0, introduced by the government, reduced the previous multi-tax structure to a two-slab structure of 5% and 18%, except for taxing sin goods at 40%.[1] It was aimed to significantly reduce the tax burden on the consumers by rationalising prices and lowering inflation. These objectives stand on the legal mandate of mandatorily passing on the benefit of tax rate reduction to consumers through a commensurate reduction in prices as required under Section 171 of the Central Goods and Services Tax Act, 2017[2] (“CGST Act”).
Despite a clear statutory framework, a critical vacuum has emerged in the enforcement of Anti Profiteering provisions. The government came up with a sunset clause[3], which bars the Authority, currently the Goods and Services Tax Appellate Tribunal (“GSTAT”), from accepting any new request for examination on anti-profiteering matters after 1st April 2025. Thus, now there is no specialized tax compliance body to adjudicate and investigate the new pricing behaviors post-GST 2.0 rollout. This institutional void has created a significant trust deficit among consumers regarding the anti-profiteering framework in India, as evident from the Local Circles survey[4] conducted across 374 districts. It presents that 87% of surveyed consumers are now demanding a revived anti-profiteering authority. It further presents that 75% of consumers remain skeptical of brand compliance. This distrust is created by the fact that only 22% of consumers surveyed confirmed receiving[5] the full benefit of rate cuts on packaged food products one month after the reform, while many other product categories saw no significant impact. It leads to concerns among consumers that businesses might be adopting disguised pricing strategies to set off the tax cut. These illicit business practices may include base price manipulation, where businesses often raise their base price before a tax reduction to offset the GST rate cut, keeping the new MRP similar to the previous one, and deceptive grammage changes, where the firm, instead of cutting the price, offers more products at the same price.[6]
While forums, such as Consumer Courts, the Legal Metrology Department, or the Competition Commission of India, have jurisdiction to address the issues of consumers, they are fundamentally unequipped to handle the profiteering disputes due to their technical and tax specific nature involving complexities like Input Tax Credit (“ITC”) adjustment, base price shifting, etc. Further these forums have limited jurisdiction and powers to address specific matters such as anti-competitive behavior and unfair trade practices which do not comprehensively cover the issues created by anti-profiteering. This inadequacy raises the question of whether the sunset clause barring new complaints before the GSTAT creates a critical regulatory gap that the existing consumer protection and competition laws cannot effectively address.
This article argues that sunset clause barring fresh anti-profiteering complaints before the GSTAT has created a critical enforcement vacuum that existing legal frameworks are ill-equipped to address. Firstly, it investigates the institutional evolution of Section 171 to demonstrate how the anti-profiteering framework has transitioned from an active enforcement mechanism to a regulatory vacuum. Secondly, it evaluates the structural limitations of alternative legal forums in addressing the profiteering disputes. Thirdly, it analyses the computation challenges surrounding commensurate reduction and highlights the need for a predictable, formula-based methodology. Fourthly, it examines the illicit business practices, such as base price manipulation and deceptive grammage changes, that may exist in this enforcement vacuum. Ultimately, it contends that safeguarding consumer welfare after GST 2.0 requires an institutionalised, formula-driven anti-profiteering mechanism, heavily diverging from previous flawed models.
FROM WATCHDOG TO VACUUM: THE EVOLUTION OF SECTION 171
The provisions for anti-profiteering are provided in Section 171 of the CGST Act[7] read with Chapter XV of the CGST Rules[8]. Before GST, there existed multiple central and state indirect taxes. GST was introduced to replace them to simplify compliance and reduce the tax burden on consumers.[9] The anti-profiteering provisions were added with the intent to ensure that the ultimate benefit of any tax reduction is received by the end consumer.[10] However, in the 15thGST Council Meeting[11], reservations were expressed that the Anti-profiteering clause would lead to ‘raid raj’ where the businesses would not have freedom to operate as per the market forces. It was suggested that as the spirit of this provision was to help in the transition to GST, the Anti-profiteering Rules should have a sunset clause of nine months or one year. The discussion continued in the 17th GST Council meeting[12], but ultimately the provisions were drafted without a sunset clause.
The Anti-Profiteering provisions ultimately paved the way for the constitution of the National Anti-Profiteering Authority(“NAA”), which would act as a responsible watchdog and an adjudicator over anti-profiteering in the market. The NAA had the power, to determine whether any reduction in the rate of tax been passed on to the recipient by way of commensurate reduction in prices, and to order remedies such as reduction in prices, return to the recipient the amount not passed.[13] However, NAA faced persistent challenges of opaque and ambiguous methodology, which often led to arbitrary proceedings.[14]
In November 2022, the powers and functions to examine anti-profiteering matters were transferred to the Competition Commission of India (“CCI”)[15]. However, However. CCI has expressed its inability to handle anti-profiteering cases as they require detailed examination of GST-specific issues such as computation of commensurate reduction, input tax credit adjustments, tax incidence, and pricing methodology and has requested that adjudication of anti- profiteering matters may be given to an appropriate GST authority.[16]. Thereafter, through amendments in Sections 109 and 171 of the CGST Act, these functions were transferred to GSTAT[17]. The amendment also introduced a proviso which gave the government power to specify a sunset date from which the Anti Profiteering Authority shall not accept any request for examination. In light of the same, 1st April 2025 was declared as the date from which the Authority shall not accept any new request for examination.[18] The Government believed that, as GST has already stabilised, market forces would take care of the reduction in prices in case of rate reduction. However, GST 2.0 has introduced substantial restructuring of tax rates across sectors and the assumption that market forces alone would ensure the seamless pass-through of tax benefits stands significantly weakened. The fresh rationalisation of GST rates has revived the concerns that Section 171 sought to address, which makes effective anti-profiteering enforcement indispensable.
The current position is that while GSTAT is adjudicating pending anti-profiteering cases, it is not accepting any new matters. It creates a situation of non-enforcement of the anti-profiteering provision, especially in light of GST 2.0, and leaves consumer welfare on the whims of market forces. GSTAT, by exercising power under Rule 126 of the CGST Rules, 2017,[19] introduced the GSTAT (Anti-profiteering) Methodology and Procedure Rules, 2025. Paragraph 7 of it provides the inherent power of examination of anti-profiteering without any complaint from an interested party.[20] However, there exists legal ambiguity on whether this power can be used by GSTAT to examine the pricing of products suo moto to determine if the benefit of rate reduction has been passed to consumers. Presently, there are no reported cases yet where the GSTAT has taken up any anti-profiteering matter suo moto.[21] It leads to legal uncertainty on the enforcement of Section 171 and has left it as a sleeping provision.
CURRENT LEGAL RECOURSE FOR ANTI PROFITEERING DISPUTES
Now, with GSTAT barred from accepting new complaints post sunset date, an enforcement vacuum has emerged. The consumers can approach alternative forums not specialised for tax adjudications. Different laws like the Consumer Protection Act, 2019, the Competition Act, 2002, and the Legal Metrology Act, 2009 provide a framework for the welfare of consumers, which can be applied to check profiteering.[22] However, it may lead to litigation across forums without effective results, as none of them can act as a substitute for a specialized tax authority like NAA under GST law.
One possible recourse would be available under the Consumer Protection Act 2019, particularly through powers of Central Consumer Protection Authority (“CCPA”) under Section 18 and 20.[23] The provisions allow CCPA to investigate ‘unfair trade practices’ such as misleading prices and overcharging the consumer.[24] Though profiteering by businesses can be covered under the Act, this route places a higher evidentiary burden on complainants, requiring them to prove that the benefit was not passed to them. It involves complex analysis of business costs and internal data, which is typically inaccessible to a consumer. Moreover, the remedy would be limited to a corrective action for individual consumers rather than a preventive action addressing systematic market behaviour.
The GST Council believed that market competition would force businesses to pass on the benefit of tax reduction to the consumers. The Competition Act 2002 deals with consumer welfare in a competitive market, but offers limited recourse for anti-profiteering.[25] The Act targets anti-competitive agreements under Section 3 and abuse of dominant position under Section 4. If a firm is by itself not transferring the benefit of a tax cut to the customer, then it will not come under the ambit of anti-competitive agreements because the section specifically envisages that for any act to come under the ambit of section 3, there must be an anti-competitive agreement between two or more firms or enterprises.[26] The business may individually decide not to pass the benefit to the consumer, irrespective of the behaviour of other enterprises, and would not violate Section 3 of the Competition Act. The framework would also fail in oligopolistic markets (like telecom or cement) where competitors may independently choose to absorb tax cuts without formal collusion. This may lead to an action under the Competition Act for abuse of dominant position under Section 4. However, it is first to be proved that the enterprise has a dominant position, which requires a higher threshold of evidence and requires complex market definition, relevant product/ geographic market, market shares, entry barriers, etc.[27] Thus, while it provides a theoretically possible solution in extreme cases, it is not a practical general remedy for widespread profiteering following GST rate cuts.
The Legal Metrology Act is equally restricted, governing only pre-packaged commodities and leaving the entire service sector unregulated.[28] Its scope and impact are limited, and it is not a comprehensive provision that covers all areas previously addressed by section 171 of the CGST Act.[29] Thus, while the authorities can inspect and penalise mismatches in MRP and actual sale price[30], they lack the mandate to handle systemic profiteering across industries.
It has left consumers and compliant businesses in a legal limbo, with a confusing and overlapping set of laws and no clear, unified method for resolving them. A company attempting to comply may also encounter a multi-jurisdictional nightmare. Instead of facing a single tax tribunal, simultaneous suits may be faced in consumer courts, metrology raids, and fraud allegations for the same pricing decision. Thus, the sunset of anti-profiteering enforcement has created a regulatory gap that existing legal frameworks cannot effectively address.
COMPUTATION CHALLENGE FOR COMMENSURATE REDUCTION
The CGST Act, while it has implemented Section 171 for the benefit of consumers, has left businesses in a legal void for the computation of commensurate reduction. The law does not provide a fixed methodology to compute such reduction, which led to the creation of arbitrary rules in diverse litigations, raising fundamental constitutional challenges. To understand the computation dilemma, one must look at how the GST rate reduction interacts with ITC.
The anti-profiteering laws require businesses to pass on the Net benefit to consumers, calculated as the difference between ‘Gains from Output tax and the loss from a corresponding reduced ITC’. The reduced Input Tax Credit (ITC) is due to the rate cut on the firm’s raw materials, computed not as a cost reduction/saving, but as a direct financial loss or added cost for the firm. The CGST Act does not prescribe the methodology to calculate “net benefit,”[31] and expects businesses to pass on the gross tax cut without reckoning the new cost. Therefore, expecting businesses to pass on the gross tax cut without taking into account this hidden cost is a fundamentally flawed mathematical approach.[32]
In its tenure, NAA often relied on a simplistic and rigid approach of “base price comparison” before and after the tax cut. However, this methodology failed because it ignored non-tax realities, such as cost-push inflation, raw material costs, labour, and transportation. For example, in the Jubilant Foodworks Ltd. case,[33] while the NAA acknowledged the defense of loss of ITC, it still held the company liable, since the increase in base price was more than the justified loss. Furthermore, the NAA also rejected the concept of netting off benefits - which would allow suppliers to offset the benefits of a tax reduction against other factors, such as increased costs or the value of discounts.[34] Consequently, businesses were forced to accept a non-tax cost increase entirely to remain compliant, resulting in a squeeze of margins.
Eventually, the courts stepped in to curb this arbitrary application. The Delhi High Court, in Reckitt Benckiser India Pvt. Ltd. v. Union of India[35], upheld the constitutional validity of Section 171, but it strongly warned against the NAA's “one-size-fits-all” computation methodology. The Court ruled that profiteering disputes require a case-by-case approach, explicitly stating that a uniform mathematical formula cannot be blindly applied across different industries with distinct cost structures. Further moving away from the NAA's outright rejection of "netting off," the Court held that while a failure to reduce prices creates a presumption of profiteering, this is a rebuttable presumption. Suppliers now have the legal standing to justify maintaining their base prices by providing evidence of genuine, external cost escalations.
In India, the computation methodology remains at the discretion of adjudicating authority (previously NAA, and now the GSTAT) without a fixed statutory formula. Meanwhile, other nations such as Australia have adopted a definite “Net Dollar Margin rule” ensuring that the same amount of MRP is reduced as the firm’s cost of production reduces due to a tax cut, and in any event, there must not be a price increase by more than 10%.[36] Similarly, Malaysia’s Price Control and Anti-Profiteering Act 2011[37] has a strict enforcement, where it compares businesses’ rate cut against a base/prescribed profit margin for a specific period (considering other economic factors), and any unreasonable increase beyond the baseline is considered anti-profiteering. These contrasting rules show that while other jurisdictions have adopted a formulaic approach leading to legal certainty, India is still counting on a subjective, unscientific, and biased methodology.
It is important to note that these nations were not immune to structural flaws; Australia’s model was heavily criticised by businesses for inflating administrative compliance costs,[38] while Malaysia’s rigid net-profit benchmarking led to supply shortages and forced companies to unsustainably absorb rising global input costs.[39] However, their formulaic approaches provided legal certainty, preventing arbitrary, subjective enforcement and reducing prolonged litigation.
India’s current fractured regulatory landscape suggests that the government cannot impose these models as a whole, but it can adopt their core mechanisms. Instead of the rigid profit-margin freezing of Malaysia that restricted corporate growth and drew domestic criticism, India should follow the formulaic approach of Australia. The GSTAT can incorporate a codified Net Dollar Margin formula in Rule 126 of the CGST Rules,[40] ensuring that the compliance is calculated strictly on an objective unit-cost basis while allowing businesses a dynamic percentage buffer explicitly to consider independent economic factors such as inflation or labor spikes.
ILLICIT BUSINESS PRACTICES IN THE PRETEXT OF ANTI-PROFITEERING
Although the legal obligation of Section 171 remains intact, the cessation of adjudication of disputes and non-acceptance of anti-profiteering complaints post 1st April 2025 may open doors for businesses to engage in illicit practices, directly and indirectly impacting consumer welfare by avoiding to pass on the GST rate cut benefits.
The most prominent of such illicit practices involves direct manipulation of the base price, where a business neutralizes the tax cut directly. Businesses often raise their base price before a tax reduction to offset the GST rate cut, keeping the new MRP similar to the previous one. In this regard, arguments claiming that the increase in cost components like rent or salaries by the same amount as the tax cut and is linked to the revision of the GST output rate are invalid and an excuse to pocket consumer savings, as such policy changes do not automatically impact a company’s everyday expenses.
As seen in the case of Jubilant Foodworks Ltd.,[41] the NAA found that Jubilant increased its prices more than the reasonable amount of lost ITC, despite anticipating a base price increase to compensate for the ITC loss following the GST reduction to 5%. This coincidence of a price hike exactly on the date of the tax cut appeared to be a malicious effort to unlawfully capture the net benefit. Similarly, after the GST rate was lowered from 28% to 18% on FMCG products like razors, the NAA held Hindustan Unilever Ltd. liable for increasing the base price by the same amount by which the tax had been reduced.[42]
However, in this regard, the NAA cannot compel sellers to lower prices after the tax cut. The Delhi High Court, in the case of Reckitt Benckiser, clarified that suppliers are free to adjust base prices based on relevant commercial and economic factors, as long as the benefits of reduced tax rates and input tax credits are passed on, and the prices are not used as a means to dodge statutory obligations under Section 171. For example, in case of an increase in the rate of taxes, if the same MRP is maintained after a reduction in the product's base price, anti-profiteering is not attracted.[43] Similarly, raising the base price after discounts are reduced does not constitute profiteering, as discounts are not part of the base price.[44]
Businesses also employ other deceptive practices to bypass compliance, such as manipulating the Grammage (Quantity), where the firm, instead of cutting the price, offers more products at the same price. In the Rahul Sharma Vs Reckitt Benckiser,[45] the petitioner passed on the GST rate cut benefit on Dettol handwash by increasing product quantity and not reducing the price. The Delhi High Court, later in the broader precedent of Reckitt Benckiser case held – “Section 171 mandates a reduction in prices. Offering extra quantity, which the consumer may not have wanted, is nothing but deception and curtails consumer choice,” thus not fulfilling the legal mandate.
Further, by combining the rate-reduced item into a “combo pack” that hides the price benefit or by concurrently eliminating an existing promotional discount, a company may negate the tax cut.This defense was firmly dismissed by the Delhi High Court in Sharma Trading Company vs. Union of India[46] – “a price increase cannot be sought to be justified on the ground that the quantity has been increased or that there was some scheme which justifies the price increase.” According to the Court, this strategy would defeat the entire purpose of the reduction of GST rates. Additionally, rebranding, minor product changes, advertisement, etc, due to the GST cut cannot be adjusted against the benefits to be transferred to a consumer.
Anti-profiteering violations could also have severe consequences of revenue fabrication and financial misrepresentation. When a company unlawfully retains consumer funds from a GST rate cut and books them as legitimate sales revenue, it violates the mandate to provide a “true and fair view” of its financial affairs under Section 129 of the Companies Act.[47]This artificial inflation of metrics like EBITDA and EPS misleads investors and constitutes unjust enrichment. Ultimately, the absence of a statutory authority does not eliminate enforcement risk but rather shifts it toward complex corporate compliance and securities litigation
In all likelihood, these illegal activities, whether they involve changing a product's grammage, base price, or the company's entire income statement are not separate offenses but rather related aspects of the same basic transgression: unjust enrichment. The termination of the NAA's enforcement arm for new complaints does not make these practices safe; rather, it trades one set of difficulties for another, a far more severe set. It simply transfers the enforcement risk from a single tax tribunal to a much more complex maze of consumer courts, corporate fraud investigations, and criminal trials, where the consequences are not only monetary but also existential.
CONCLUSION
The NAA sunset was not a deregulatory move but was essential for fundamental enforcement reform, as it faced heavy criticism for its inconsistent approach and arbitrary decisions that resembled price controls more than tax regulation. However, GST 2.0, introduced to simplify the tax system and reduce the burden on consumers, has created a more complex enforcement dilemma, i.e., escalating anti-profiteering from a tax dispute to intricate litigation due to a lack of a strong enforcement framework. This enforcement gap has diminished trust, with nearly 87% of citizens calling for a renewed check on pricing.[48] Further, many anti-profiteering disputes are still pending in the Delhi High Court (W.P.(C)-2347/2019), in which the Court has ordered for adjudication on a case-by-case basis.[49] It has left consumers and compliant businesses in legal uncertainty, with an overlapping set of laws, lacking a clear and unified resolution process.
Reviving the old and flawed NAA model is not the recourse to balance consumer welfare and ease of doing business. What India needs is a targeted institutional overhaul based on objective and formula-driven enforcement. Instead of leaving pricing compliance to market forces or an unsupervised tribunal, the Central Government should exercise its power under Section 164 of the CGST [50] Act to amend Rule 126 and formally introduce a statutory “Net Dollar Margin” calculation methodology in the GSTAT system. The law can lessen the arbitrary “base price comparison” model, moving away from a “case-by-case” assessment to an explicit ledger formula that mathematically offsets output tax reductions directly against certified raw material inventory valuation shifts and localized input tax credit (ITC) restrictions.
Furthermore, to avoid this framework being a static price control, the statutory rule must incorporate a dynamic ‘safe harbour’ percentage buffer that automatically shields businesses from anti-profiteering liability if price adjustments can be shown to be driven by verifiable macroeconomic shocks such as fuel hikes or labour spikes. Transforming the GSTAT’s anti-profiteering bench into a purely computational, formulaic clearance desk will swap India’s fragmented multi-jurisdictional dilemma for complete legal certainty and protection of consumer equity without affecting industrial growth.
Thus, till the time a structured framework is established, anti-profiteering redressal and consumer welfare stand on an existential risk, leaving enforcement of Section 171 of the CGST Act in a vacuum. The best interest of the consumer cannot be left to the whims of market forces; it requires a calculated and formula-driven enforcement regime.
References
[1] GST Council, 56th Meeting of the GST Council: Press Release (3 September 2025) https://gstcouncil.gov.in/sites/default/files/2025-09/press_release_press_information_bureau.pdf.
[2] Central Goods and Services Tax Act 2017, s 171.
[3] Central Board of Indirect Taxes and Customs, Notification No 19/2024–Central Tax (30 September 2024) https://gstcouncil.gov.in/sites/default/files/2024-10/19-2024-ct-eng.pdf.
[4] LocalCircles, '4 in 10 consumers get no GST rate reduction benefits across key sectors' (LocalCircles, 5 November 2025) https://www.localcircles.com/a/press/page/gst-rate-reduction-benefits accessed 30 June 2026.
[5] LocalCircles, 'GST 2.0: Consumers continue to see GST benefits when purchasing whitegoods and vehicles, but packaged foods and medicines still lag in week 3' (LocalCircles, 14 October 2025) https://www.localcircles.com/a/press/page/gst-profiteering-oct-2025 accessed 30 June 2026.
[6] Reckitt Benckiser India Pvt Ltd v Union of India 2024 SCC OnLine Del 588.
[7] Central Goods and Services Tax Act 2017, s 171.
[8] Central Goods and Services Tax Rules 2017, ch XV.
[9] Constitution (One Hundred and Twenty-Second Amendment) Bill 2014, Statement of Objects and Reasons, Bill No 192 of 2014.
[10] GST Council, Minutes of the 53rd Meeting of the GST Council (22 June 2024) 53rd_minutes_converted.pdf accessed 30 June 2026.
[11] GST Council, Minutes of the 15th Meeting of the GST Council (3 June 2017) signed-minutes-15th-gst-council_meeting.pdfaccessed 30 June 2026.
[12] GST Council, Minutes of the 17th Meeting of the GST Council (18 June 2017) signed-minutes-17th-gst-council_meeting.pdfaccessed 30 June 2026.
[13] Central Goods and Services Tax Rules 2017, r 127.Rule 127 cgst rules
[14] Reckitt Benckiser India Pvt Ltd v Union of India 2024 SCC OnLine Del 588 [68]–[75].
[15] Central Board of Indirect Taxes and Customs, Notification No 23/2022–Central Tax (23 November 2022) https://gstcouncil.gov.in/sites/default/files/2024-05/ct23-2022.pdf accessed 30 June 2026.
[16] GST Council, Minutes of the 53rd Meeting of the GST Council (22 June 2024) 53rd_minutes_converted.pdf accessed 30 June 2026.
[17] Finance (No 2) Act 2024, ss 146 and 147 (amending Central Goods and Services Tax Act 2017, ss 109 and 171); Central Board of Indirect Taxes and Customs, Notification No 18/2024–Central Tax (30 September 2024) https://gstcouncil.gov.in/sites/default/files/2024-10/18-2024-ct-eng.pdf accessed 30 June 2026.
[18] Central Board of Indirect Taxes and Customs, Notification No 19/2024–Central Tax (30 September 2024) https://gstcouncil.gov.in/sites/default/files/2024-10/19-2024-ct-eng.pdf accessed 30 June 2026.
[19] Central Goods and Services Tax Rules 2017, r 126.
[20] Goods and Services Tax Appellate Tribunal, GSTAT (Anti-profiteering) Methodology and Procedure Rules 2025, para 7.
[21] Goods and Services Tax Appellate Tribunal, Principal Bench – Anti-Profiteering Division Principal Bench, GSTAT [Antiprofiteering Division] accessed 30 June 2026.Gstat principle bench website
[22] Consumer Protection Act 2019, ss 2(47), 18; Competition Act 2002, ss 3, 4; Legal Metrology Act 2009, ss 18, 36.
[23] Consumer Protection Act 2019, ss 18, 20.
[24] Consumer Protection Act 2019, s 2(47).
[25] Competition Act 2002.
[26] Competition Act 2002, s 3.
[27] Competition Act 2002, ss 4, 19(4)–19(7).
[28] Legal Metrology Act 2009, ss 2(l), 18; Legal Metrology (Packaged Commodities) Rules.
[29] Legal Metrology Act 2009; Central Goods and Services Tax Act 2017, s 171.
[30] Legal Metrology Act 2009, ss 15, 18, 29, 36.
[31] GST Council, ‘FAQ on Anti-profiteering provisions’ (February 2024) https://www.gstcouncil.gov.in/sites/default/files/2024-02/anti-prof-faq.pdf accessed 2 July 2026.
[32] Kumar Visalaksh and Surbhi Jain, ‘GST Anti-Profiteering: The Methodology Conundrum’ (Bloomberg Quint, 27 April 2021) https://elplaw.in/wp-content/uploads/2023/10/ELP-Bloomberg-Quint-Article-GST-Anti-Profiteering-The-Methodology-Conundrum.pdf accessed 2 July 2026.
[33] Sh Kiran Chimirala chiki, Director General Anti-Profiteering, Central Board of Indirect Taxes & Customs v M/s Jubilant Food Works Ltd NAA Case No 04/2019 (31 January 2019) https://www.naa.gov.in/docs/Jubiliant%20Order.pdf accessed 1 July 2026.
[34] 2018 (12) TMI 1599 - NATIONAL ANTI-PROFITEERING AUTHORITY Sh. Ankit Kumar Bajoria, Sh. Subramanian Manjeri Ramanathan, Director General Anti-Profiteering, Central Board of Indirect Taxes & Customs Versus M/s Hindustan Unilever Limited.
[35] Reckitt Benckiser India Pvt Ltd v Union of India 2024 SCC OnLine Del 588.
[36] Australian Competition & Consumer Commission, ‘ACCC pricing guidelines firm and fair’ (Media Release, MR 111/99, 13 July 1999) https://www.accc.gov.au/media-release/accc-pricing-guidelines-firm-and-fair accessed 1 July 2026.
[37] Price Control and Anti-Profiteering (Mechanism to Determine Unreasonably High Profit) Regulations 2018 (Malaysia) PU (A) 142/2018 https://faolex.fao.org/docs/pdf/mal210817.pdf accessed 1 July 2026.
[38] SR Nair, Goods and Services Tax and Price Control Measures: Lessons for India from Australian Experience (Working Paper IIMK/WPS/227/EA/2017/11, Indian Institute of Management Kozhikode 2017) https://forms.iimk.ac.in/websiteadmin/FacultyPublications/Working%20Papers/227fullp.pdf accessed 1 July 2026.
[39] Hafiz Noor Shams, Anti-profiteering Regulations: Effects on Consumer Prices & Business Margins (Policy IDEAS № 47, Institute for Democracy and Economic Affairs 2017) 16.
[40] Central Goods and Services Tax Rules 2017, r 126.
[41] Sh Kiran Chimirala chiki, Director General Anti-Profiteering, Central Board of Indirect Taxes & Customs v M/s Jubilant Food Works Ltd NAA Case No 04/2019 (31 January 2019) https://www.naa.gov.in/docs/Jubiliant%20Order.pdf accessed 1 July 2026.
[42] Ankit Kumar Bajoria vV. Hindustan Unilever Limited 2018 SCC ONLINE NAA 20.
[43] Smt. Mandalika Sakunthala, Director General Anti-Profiteering, Central Board of Indirect Taxes & Customs v M/s Fabindia Overseas Pvt Ltd NAA Case No 13/2018 (16 November 2018) https://www.naa.gov.in/docs/1542629737FAB%20India.pdf accessed 1 July 2026.
[44] Director General of Anti-Profiteering & Ors v M/s Asian Paints Ltd NAA Case No 29/2018 (27 December 2018) https://www.naa.gov.in/docs/154591480329-2018.pdf accessed 1 July 2026.
[45] 2020 (4) TMI 571 - NATIONAL ANTI-PROFITEERING AUTHORITY Sh. Rahul Sharma, M/s. Local Circles (I) Pvt. Ltd., Director General of Anti-Profiteering, Indirect Taxes and Customs Versus M/s. Reckitt Benckiser India Pvt. Ltd. and M/s. Affiniti Enterprises
[46] Sharma Trading Company v. Union of India & Ors 2025 (10) TMI 57.
[47] Companies Act 2013, s 129.
[48] LocalCircles, '3 in 4 consumers are sceptical of brands passing reduced GST rates' (LocalCircles Press Release, 9 September 2025) https://www.localcircles.com/a/press/page/gst-rate-reduction-benefits accessed 2 July 2026.
[49] JUBILANT FOODWORKS LTD. & ANR. VS. UNION OF INDIA & ORS W.P.(C) - 2347 / 2019
[50] Central Goods and Services Tax Act 2017, s 164.
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