GST cancellation notices lacking clear particulars and application of mind can be quashed, with registration restored.

An incomprehensible system-generated GST cancellation notice that failed to state the factual basis for cancellation, and a mechanically issued order showing non-application of mind and internal inconsistency about whether a reply had been filed, were held liable to be quashed. The availability of revocation under Section 30 of the CGST Act did not bar writ relief where the digital process itself was defective and an effective response could not be made. Physical notices and orders were directed until the system issue was resolved, and the GST registration was ordered to be restored forthwith.

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Issues: Whether an incomprehensible, system-generated show cause notice and cancellation order, issued without proper particulars and displaying non-application of mind, were liable to be quashed and whether the petitioner's GST registration was to be restored.

Analysis: The notice did not clearly allege the factual basis for cancellation and was not intelligible enough to enable an effective reply. The cancellation order was also internally inconsistent, referred to both the absence and existence of a reply, and reflected a mechanical exercise rather than an application of mind. In these circumstances, the availability of revocation under Section 30 of the Central Goods and Services Tax Act, 2017 did not displace the writ remedy. The defects in the digital process were treated as serious enough to require issuance of notices and orders in physical form until the system issue was resolved.

Conclusion: The notice and cancellation order were quashed and the respondents were directed to restore the petitioner's registration forthwith.

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