By S&S Co. Advocates & Solicitors · Published 28 September 2026 · Informational content, not legal advice: see our disclaimer
Overview
A guide for a business currently facing, or previously subject to, a GST anti-profiteering investigation, explaining that the Central Government has stopped accepting new anti-profiteering complaints from 1 April 2025, what happens to complaints and investigations already underway, and which forum now decides them.
What You Need to Know
- The Central Government notified 1 April 2025 as the sunset date for the anti-profiteering provisions under GST: no new anti-profiteering complaints or investigations can be initiated after that date
- Section 171 of the CGST Act itself remains on the statute book unchanged, continuing to require that any reduction in GST rate or benefit of additional input tax credit be passed on to the recipient by way of a commensurate reduction in price: the sunset affects new enforcement, not the underlying substantive obligation
- The anti-profiteering enforcement function has passed through three institutional homes over time: the erstwhile National Anti-Profiteering Authority (NAA), then the Competition Commission of India (which took over jurisdiction from 1 October 2024), and now the Principal Bench of the GST Appellate Tribunal (GSTAT)
- Complaints and investigations that were already underway, meaning a DGAP investigation report or a hearing notice had already issued, before the 1 April 2025 sunset continue to be adjudicated to conclusion by the GSTAT Principal Bench, regardless of the sunset date
- A business currently defending a pending anti-profiteering matter should confirm the current procedural stage of its case and the GSTAT Principal Bench's applicable timelines, since the Bench has continued issuing final orders on legacy cases through 2026
- Businesses should not assume the sunset means Section 171's substantive price-pass-through obligation has disappeared, pricing decisions around a GST rate reduction should still account for the statutory pass-through requirement, even though the enforcement mechanism for new complaints has closed
Frequently Asked Questions
Can a business still face a new anti-profiteering complaint today?
No: the Central Government stopped accepting new anti-profiteering complaints and investigations from 1 April 2025, though Section 171's underlying price-pass-through obligation remains on the statute book.
Who decides anti-profiteering complaints that were already pending before the sunset?
Complaints and investigations already underway before 1 April 2025 continue to be adjudicated to conclusion by the Principal Bench of the GST Appellate Tribunal (GSTAT), which took over after the erstwhile NAA and a stint with the CCI.
Does the sunset mean businesses no longer need to pass on a GST rate cut?
No: Section 171 itself is unchanged, so a business should still account for the statutory pass-through requirement when pricing a GST rate reduction, even though the enforcement mechanism for new complaints has closed.
References & Further Reading
This guide references the following statutes, rules and sources, cross-checked at the time of writing.
- 1 April 2025 sunset date for new anti-profiteering complaints/investigations: confirmed via ClearTax and ICSI journal coverage at research time
- Institutional transition from NAA to CCI (from 1 October 2024) to GSTAT Principal Bench: confirmed via CAalley's explainer and TaxGuru coverage at research time
- Pending pre-sunset cases (with an issued DGAP report or hearing notice) continuing to be decided by GSTAT Principal Bench: confirmed via research-time sources: verify the current GSTAT Principal Bench operational status and any further procedural notification at drafting time, since GSTAT's own rollout has been a live, evolving process
- See also our Tax Litigation Notable Judgments and Legal Updates: Tax Litigation archive.