Mandatory GST notice format vitiates registration cancellation when prescribed hearing particulars are omitted.

GST registration cancellation under the Tamil Nadu GST Rules was held unsustainable where the show cause notice was not issued in the prescribed FORM GST REG-17 and omitted the date and time of personal hearing required by Rule 22(1). The court treated compliance with the statutory notice format and hearing particulars as mandatory before cancellation under Section 29, and set aside the cancellation order because the prerequisite notice was defective. No view was taken on the alleged default on merits.

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Issues: Whether the order cancelling GST registration was liable to be set aside for non-compliance with Rule 22(1) of the Tamil Nadu Goods and Services Tax Rules, 2017, inasmuch as the show cause notice did not specify the date and time of personal hearing.

Analysis: Rule 22(1) requires the proper officer, before cancelling registration under Section 29 of the Tamil Nadu Goods and Services Tax Act, 2017, to issue a notice in FORM GST REG-17 calling upon the person to show cause. The notice placed on record was not in the prescribed template because it omitted the particulars of the date and time of personal hearing. Since the respondent also accepted that the records did not reveal issuance of the notice in the prescribed REG-17 format, the cancellation order could not be sustained. No opinion was expressed on the merits of the alleged default.

Conclusion: The cancellation order was set aside as the prerequisite show cause notice did not comply with the prescribed format and mandatory hearing particulars.

Ratio Decidendi: Where registration is proposed to be cancelled, failure to issue the show cause notice in the prescribed statutory form with the required personal hearing particulars vitiates the cancellation order.

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