Fair hearing and reasoned orders govern GST registration cancellation; procedural dismissal without merits can lead to remand.

Cancellation of GST registration cannot be sustained where the taxpayer was not given an effective opportunity to reply to the show-cause notice and the order contains no reasoned consideration of the explanation; such an order, carrying civil consequences, must reflect application of mind and be supported by reasons, so it was set aside. An appellate authority cannot reject the challenge only on limitation and online-filing non-compliance without merits-based scrutiny where fresh consideration is required; the appellate order was set aside and the matter remanded to the original authority for a fresh, reasoned decision after hearing the taxpayer.

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Issues: (i) Whether the order cancelling GST registration could be sustained when the petitioner was not afforded an effective opportunity to answer the show cause notice and the order was not supported by reasons; (ii) Whether the appellate order rejecting the appeal only on limitation and procedural non-compliance could stand, and whether the matter required remand for fresh consideration.

Issue (i): Whether the order cancelling GST registration could be sustained when the petitioner was not afforded an effective opportunity to answer the show cause notice and the order was not supported by reasons.

Analysis: The cancellation order proceeded on the basis that no reply had been submitted, while the petitioner had sought time to file a reply and to discharge the dues. The order did not contain any real discussion of the petitioner's explanation or the surrounding circumstances and was not a reasoned decision on merits. An order affecting registration and civil consequences must be passed after a fair opportunity and must reflect application of mind.

Conclusion: The cancellation order could not be sustained and was set aside.

Issue (ii): Whether the appellate order rejecting the appeal only on limitation and procedural non-compliance could stand, and whether the matter required remand for fresh consideration.

Analysis: The appellate authority declined to examine the merits and dismissed the appeal on limitation and online-filing grounds alone. In the circumstances, the matter called for consideration on merits by the original authority after granting an opportunity of reply and personal hearing. The appropriate course was to restore the controversy to the adjudicating authority for a fresh decision in accordance with law.

Conclusion: The appellate order was set aside and the matter was remanded for fresh consideration.

Final Conclusion: The impugned cancellation and appellate orders were annulled, and the dispute was sent back to the original authority for a fresh, reasoned decision after granting opportunity of hearing.

Ratio Decidendi: A statutory order having civil consequences, including cancellation of GST registration, must be supported by reasons and passed after a meaningful opportunity of hearing; where the appellate authority refuses merits-based scrutiny and disposes of the appeal only on procedural grounds, remand for fresh adjudication is warranted.

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