Natural justice in GST cancellation demands specific notice particulars and hearing before any adverse order is passed.

A show cause notice for GST registration cancellation must contain material particulars, including the relevant period and quantum of alleged wrongful input tax credit, so the noticee can give an effective reply. An authority also cannot pass a cancellation order before the hearing date fixed in the notice, because doing so denies a meaningful opportunity of hearing and violates natural justice. The challenged notice and cancellation order were therefore set aside.

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Issues: Whether the show cause notice and the order cancelling GST registration were vitiated for violation of natural justice and were liable to be set aside.

Analysis: The petitioner challenged the cancellation of GST registration under Article 226 of the Constitution of India. The notice required appearance on a future date, yet the cancellation order was passed before that date. The notice was also found to be vague because it did not specify the quantum or period of the alleged wrongful availment of input tax credit, depriving the noticee of a meaningful opportunity to respond. A notice that lacks essential particulars cannot sustain a proceeding, and deciding the matter before the notified hearing date was held to be unjust and contrary to natural justice.

Conclusion: The show cause notice and the cancellation order were set aside, and the challenge succeeded in favour of the petitioner.

Ratio Decidendi: A show cause notice must contain material particulars sufficient to enable an effective reply, and an authority cannot decide a matter before the date fixed for hearing; a proceeding so conducted is vitiated by violation of natural justice.

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