Natural justice in VAT registration cancellation requires proper notice, hearing, and statutory compliance before any cancellation order can stand.

Cancellation of registration under the Tamil Nadu Value Added Tax Act, 2006 is invalid unless the dealer is given proper notice, a real opportunity of hearing, and compliance with the prescribed procedure. The High Court noted that Section 39(14) and (15) require good and sufficient reasons for cancellation and a hearing before any order is made, while Rule 19 prescribes the service procedure. Because service by affixture was not supported by the order and proper notice and hearing were not shown, the cancellation breached statutory procedure and natural justice. The cancellation order was therefore set aside, with liberty to proceed afresh in accordance with law.

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Issues: Whether cancellation of the petitioner's registration under the Tamil Nadu Value Added Tax Act, 2006 was valid when notice was not properly served and no opportunity of hearing was given.

Analysis: Section 39(14) and (15) of the Tamil Nadu Value Added Tax Act, 2006 require good and sufficient reasons for cancellation of registration and mandate that the dealer be given an opportunity of being heard before any order of cancellation is made. The asserted service by affixture was not supported by the impugned order, and the prescribed procedure under Rule 19 of the Tamil Nadu Value Added Tax Rules, 2007 was not shown to have been followed. The absence of proper notice and personal hearing amounted to violation of the statutory procedure and the principles of natural justice.

Conclusion: The cancellation order was unsustainable and was set aside, with liberty to proceed afresh in accordance with law.

Ratio Decidendi: An order cancelling registration under Section 39 of the Tamil Nadu Value Added Tax Act, 2006 is invalid unless the dealer is given proper notice and an opportunity of hearing in the manner prescribed by law.

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