Non-application of mind in GST registration cancellation renders the order arbitrary and makes the limitation issue infructuous.

GST registration cancellation was quashed because the cancellation order reflected non-application of mind: it proceeded on an alleged reply and personal hearing even though the record showed no reply was filed and no hearing was attended. That inconsistency made the cancellation arbitrary. Once the cancellation order was set aside, the challenge to the appellate order dismissing the appeal as time-barred did not survive and became infructuous. Relief was made subject to filing of returns within the stipulated period.

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Issues: Whether the cancellation of GST registration was liable to be quashed for lack of application of mind in the cancellation order, and whether the dismissal of the appeal on limitation survived independently.

Analysis: The cancellation order recorded that the registration should be cancelled on the basis of an alleged reply and personal hearing, even though the record showed that no response had been filed and no personal hearing had been participated in. This inconsistency demonstrated non-application of mind and rendered the cancellation arbitrary. In view of the quashing of the cancellation order, the challenge to the appellate order dismissing the appeal on delay did not survive for consideration.

Conclusion: The cancellation of GST registration was quashed, subject to filing of returns within the stipulated period, and the dismissal of the appeal on limitation was rendered infructuous.

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