GST cancellation notice must disclose material particulars; undisclosed grounds and extra-notice reliance violate natural justice.

A GST registration cancellation cannot stand where the show cause notice omits material particulars and fails to state the factual basis for alleging fraud, wilful misstatement, or suppression of facts. The cancellation order was invalid because it went beyond the notice and relied on investigation material and undisclosed grounds, depriving the assessee of a fair opportunity to respond. That procedure was contrary to natural justice and illegal. The notice and cancellation order were quashed, the matter was remitted for de novo proceedings, and registration was directed to be restored.

---

---

Issues: Whether the show cause notice for cancellation of GST registration and the consequential cancellation order were sustainable when they did not disclose material particulars and relied upon grounds not put to the assessee.

Analysis: The show cause notice was found to be bereft of material particulars and did not disclose the factual basis on which the authority formed a prima facie view that registration had been obtained by fraud, wilful misstatement, or suppression of facts. The cancellation order travelled beyond the notice by relying on investigation material and facts not disclosed to the assessee in the notice, thereby depriving the assessee of a fair opportunity to respond. Such procedure was held to be contrary to the principles of natural justice and illegal.

Conclusion: The show cause notice and the cancellation order were quashed and set aside, the matter was remitted for de novo proceedings, and the GST registration was directed to be restored.

Ratio Decidendi: A cancellation of GST registration cannot be sustained where the notice lacks material particulars and the final order is founded on undisclosed grounds or material, as this violates natural justice and the requirement of a meaningful opportunity of hearing.

---