Taxpayer Wins GSTN Registration Restoration, Successfully Challenges Time-Barred Appeal with Comprehensive Tax Resolution Strategy

HC quashed Reference No.ZA330421207302D and Appeal no.MAD-CGST-JTC-APP-087, reinstating petitioner's GSTN registration. Despite appeal being beyond limitation period, court followed consistent precedent allowing taxpayer to file returns, pay defaulted taxes with interest, and resolve Input Tax Credit issues. Judgment aligned with previous rulings, providing relief to petitioner without imposing additional costs.

---

---

Issues:
1. Quashing of Reference No.ZA330421207302D and order in Appeal no.MAD-CGST-JTC-APP-087
2. Cancellation of petitioner's GSTN Registration No. 33CULPS7963K1ZR
3. Rejection of appeal on the ground of limitation
4. Legal sustainability of rejection of appeal beyond the period of limitation
5. Consistent view in similar matters by the Court
6. Benefit extension to the petitioner based on previous judgments

Analysis:
1. The writ petition sought to quash Reference No.ZA330421207302D and the order in Appeal no.MAD-CGST-JTC-APP-087, along with the cancellation of the petitioner's GSTN Registration No. 33CULPS7963K1ZR, deeming them illegal and arbitrary. The petitioner was unaware of the registration cancellation until informed by other taxpayers. An appeal was filed but rejected due to being beyond the limitation period.

2. The petitioner's counsel cited a previous case where the Court issued specific directions in similar circumstances. These directions included filing returns for the period before cancellation, paying defaulted taxes with interest and fines, not using unutilized Input Tax Credit, and getting approval for any utilized credit before future use. The Court had consistently followed these directions in subsequent cases.

3. The Respondent's Senior Standing Counsel argued that the appellate authority must adhere to the prescribed limitations, making the rejection of the appeal beyond the limitation period legally valid. The Court noted a consistent view in such matters, with the revenue not challenging previous orders, indicating their acceptance.

4. Given the Court's consistent approach and the Revenue's acceptance of previous judgments, the Court decided to extend the benefit granted in earlier cases to the petitioner. The Court ordered the writ petition in line with the terms mentioned in a specific paragraph of a previous judgment, ensuring no costs were imposed. The connected miscellaneous petitions were also closed as a result of this decision.

---