Godfrey Phillips India Ltd

Mr. Kusumakar Pandey, Chief Risk Officer ceased to be a Member of the Risk Management Committee with effect from 31st January 2026.

Mr. Siddharth Chawla was appointed as Chief Risk Officer and member of the Risk Management Committee with effect from 1st February 2026.

Department appeal is pending before CESTAT. There was no material development on the matter during the quarter ended on 31st March 2026.

This issue pertains to classification of “Tipper” Brand Cigarette for the purposes of levy of excise duty. The Company had classified this Cigarette under the heading “Other than Filter Cigarette”. The Central Excise Department (the Department) alleged that the Cigarette manufactured were “Filter Cigarette” and acc ordingly demanded the differential excise duty by issuing show cause notices for the period from 2006 to 2009. The Company initially received a favorable order by the Commissioner in the year 2009 against which the Department filed an appeal before the CESTAT Mumbai and the CESTAT remanded the matter for fresh adjudication by the Commissioner. In second round of litigation by virtue of remand, entire demand was dropped in June 2020 by the Commissioner, Mumbai accepting the classification adopted by the Company as “Other than Filter Cigarettes” as against “Filter Cigarettes” alleged by the Department. The Department has once again filed the appeal before the CESTAT, Mumbai in October 2020 and the matter is pending adjudication.

The Company has received a show cause notice (SCN) in April 2022 issued by the DGGSTI, Delhi alleging that Input Tax Credit (ITC) relating to the period July 2017 to June 2018 and pertaining to the services availed/ procured at Head Office/Corporate Office of the Company and subsequently cross charged to all establishments and Goods & Service Tax (GST) registrations of the Company across the country, is ineligible for credit at the Head Office/Corporate Office of the Company since it was not registered as Input Service Distributor (ISD). Hence, in view of the DGGSTI, the ITC availed by the Company becomes recoverable with applicable interest and penalty. The Company had adopted the cross-charge mechanism instead of ISD basis the legal advice obtained by it. Recently this issue has also been covered by the CBIC in its Circular No.199/11/2023-GST dated 17.07.2023 which appears to have the effect of clarifying that as per the present provisions of the CGST Act and CGST Rules, it is not mandatory for the Head Office of a company to distribute ITC by ISD mechanism alone and appears to be meant to provide relief to the taxpayers who have adopted the cross-charge mechanism. The matter is at the SCN stage and is yet to be adjudicated by the Additional Commissioner. The Additional Commissioner, Central Goods & Service Tax, Delhi East, has passed an Order on 3rd February 2025: a) Confirming the demand of wrongly availed Input Tax Credit amounting to Rs. 27.72 Crore; b) Levying interest on the above referred amount at appropriate rate (amount not calculated) in terms of provisions of Section 50 of the CGST Act, 2017; c) Imposing penalty amounting to Rs. 27.72 Crore u/s 74(1) of the CGST Act, 2017; d) Imposing penalty amounting to Rs. 27.06 Crore for issuing invoices without supply of goods or services or both; e) Imposing penalty of Rs. 27.72 Crore for not obtaining Input Service Distributor Registration as applicable under the CGST Act, 2017; and f) Imposing penalty of Rs. 50,000 each upon two officials of the Company. The Company, based on its assessment and considering the legislative changes having taken place since issuance of the SCN, believes that it has a good case on merit and during the quarter ended 30th June 2025, the Company has filed the appeal before the Commissioner (Appeals).

The Department has alleged that the Company has short paid excise duty on the manufacture of pan masala during the period July 2010 to September 2012 in terms of Pan Masala Packing Machines (Capacity Determination and Calculation of Monthly Duty Liability) Rules, 2008 (hereinafter referred as the Pan Masala Rules) and accordingly issued show cause notices (SCNs) based on Duty Determination Orders passed by the Assistant Commissioner, Baramati. The key contentions raised by the Department in the SCNs are summarised as under: (1) Excise duty is payable for complete month even though a packing machine is operated for part of the month (except where whole factory is closed for continuous period of at least 15 days) and abatement of excise duty, if any, shall be claimed subsequently. (2) Packing machines which have been sealed by the Department (but not uninstalled/removed from the factory) shall also be charged to excise duty. (3) Where the Company has operated more than one retail sale price (RSP) (Say Rs. 2 and Rs. 4) on separately assigned packing machines, each packing machine shall be counted as two machines as if each such machine is used for the manufacture of both such RSP and excise duty liability shall be computed accordingly. The Company appealed before the CESTAT, Mumbai which then remanded back the matter for fresh adjudication by the Department and the same is now pending before the Commissioner, Pune. By orders passed in February and March 2025, the SCNs covering duty amount of Rs. 79,42,46,201 have been decided in favour of the Company and the SCNs covering duty amount of Rs. 3,18,32,259 have been decided against the Company with levy of applicable interest and pentaly thereon. The Company has filed appeals against the two orders covering duty amount of Rs. 3,07,00,000 and has decided to pay the balance confimred demands of Rs.11,32,259 with applicable interest and penalty before CESTAT.

Order passed confirming demand of GST of Rs. 70,33,94,442/- and GST Compensation Cess of Rs. 12,56,06,150/- with applicable interest (amount not calculated) and imposing penalty of Rs. 82,90,00,592/- under the Central Goods and Services Tax Act, 2017 read with the relevant provisions of the Maharashtra GST Act, 2017 and the GST (Compensation) Act, 2017 for alleged undervaluation of supply of goods resulting in short payment of tax under the GST laws.During the quarter ended 30th June 2025, the Company has filed the appeal before the Commissioner (Appeals).