Where anti-profiteering proceedings under Section 171 of the CGST Act were referred beyond the period in Rule 128, the timeline being directory did not vitiate the proceedings, and GST collected on the higher price formed part of the profiteered amount refundable with 18% interest, with penalty under Section 171(3A) attracted from 01.01.2020 onwards – Director General of Anti-Profiteering (DGAP) Vs. Siddha Infradev LLP – GSTAT Principal Bench