Writ relief against GST registration cancellation may be available where limitation bars appeal and livelihood is affected.

Where GST registration is cancelled for non-filing of returns and the statutory appeal is time-barred, writ relief under Article 226 may still be considered in an appropriate case if strict limitation would leave the assessee remediless and impair livelihood. The article notes a restorative approach to registration, recognising that the GST framework is meant to facilitate legitimate trade and revenue collection rather than permanently exclude a trader for procedural default. On that basis, cancellation need not operate as an absolute bar where revival safeguards can be applied.

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Issues: Whether cancellation of GST registration and rejection of the revocation request could be interfered with under writ jurisdiction despite expiry of the statutory appellate limitation, having regard to the assessee's livelihood and the object of the GST regime.

Analysis: The order notes that the petitioner's registration was cancelled for non-filing of returns and the statutory appeal was stated to be unavailable because the limitation period had expired. The Court considered the hardship caused by loss of GST registration to a small trader, the impact on the right to carry on business and livelihood, and the line of decisions that treat restoration of registration as appropriate where rigid procedural limits would leave the assessee remediless. The Court also referred to the need for the GST framework to facilitate legitimate trade and collection of revenue rather than permanently exclude an assessee from the tax fold for procedural default.

Conclusion: The Court declined to let the cancellation stand as an absolute bar and disposed of the writ petition in terms of the principles and safeguards governing revival of GST registration.

Final Conclusion: The petitioner obtained a partial substantive relief in writ jurisdiction, with the matter being resolved by applying the restorative approach recognised in the cited GST registration cases.

Ratio Decidendi: In an appropriate case, Article 226 may be invoked to grant relief against cancellation of GST registration where strict enforcement of limitation would defeat livelihood and exclude the assessee from the GST regime without a meaningful remedy.

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