The time limit of six months prescribed under Rule 133 of CGST Rules is directory in nature | Since the provisions of Section 171(3A) of the CGST Act for imposition of penalty have come into force w.e.f. 01.01.2020 whereas the period of investigation 01.07.2017 to 30.09.2019, hence the penalty prescribed under the above Section cannot be imposed retrospectively – Director General of Anti-Profiteering (DGAP) Vs. A J Enterprises – GSTAT Principal Bench

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