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Issues: Whether the cancellation of GST registration, the rejection of the revocation application, and the appellate order were sustainable when the show cause notice and consequential orders did not specify a legally permissible ground under Section 29(2) and denied a meaningful opportunity of hearing.
Analysis: Cancellation of registration has serious civil consequences and, once registration has been granted, the authority must clearly establish the statutory basis for cancellation. Section 29(2) permits cancellation only on the specified grounds, and the expression "bogus" by itself is not a statutory ground. The notice and the orders did not disclose which clause of Section 29(2) was invoked, did not set out the factual foundation of the alleged default, and did not confront the assessee with the adverse material. The revocation proceedings were also defective because no effective date and time of hearing was fixed, and the rejection order remained non-speaking. The appellate authority could not sustain these defects by introducing its own reasons when the original orders themselves lacked the necessary statutory basis and procedural fairness.
Conclusion: The cancellation, rejection of revocation, and appellate order were unsustainable and were rightly set aside. The assessee succeeded, and the authority was left free to issue a fresh notice on a specified ground under Section 29(2).
Ratio Decidendi: A registration under the GST regime can be cancelled only on a clearly specified statutory ground, and a vague allegation such as "bogus" without disclosure of the exact clause, factual basis, and supporting material violates natural justice and cannot sustain cancellation or refusal of revocation.
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