GST registration revocation despite delay permitted where cancellation affected livelihood, subject to return compliance and prompt consideration.

Cancellation of GST registration was treated as causing business hardship and affecting livelihood, so the HC allowed revocation proceedings to be pursued despite the application being time-barred. The statutory remedy under Section 30 of the Uttarakhand GST Act, 2017 read with Rule 23 of the Rules remained available, but the petitioner was required to file the revocation application within 21 days and comply with return-filing obligations for the defaulted period and subsequent completed months. The revenue was directed to consider the matter liberally and decide it expeditiously if dues were identified and paid.

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Issues: Whether the petitioner could be permitted to seek revocation of cancellation of GST registration under the relevant GST provisions despite delay, and whether the authority should consider the application after compliance with return-filing requirements.

Analysis: The cancellation had resulted in hardship affecting the petitioner's ability to carry on business and, by extension, the livelihood of persons engaged with the business. The statutory remedy for revocation under Section 30 of the Uttarakhand GST Act, 2017, read with Rule 23 of the Uttarakhand GST Rules, 2017, was available, but the application was time-barred. In view of the livelihood implications, the Court waived the limitation, directed filing of the revocation application within 21 days, and required compliance with the return-filing obligations for the defaulted period and subsequent completed months. The revenue was directed to consider the matter liberally and dispose of it expeditiously if dues were found and paid.

Conclusion: The petitioner was permitted to pursue revocation of GST registration, and the delay in moving the application was condoned in the circumstances.

Ratio Decidendi: Where cancellation of GST registration threatens livelihood, the Court may, in appropriate circumstances, direct revocation proceedings to be entertained notwithstanding delay, subject to statutory compliance.

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