Extended GST revocation amnesty can revive cancelled registration, with relief available subject to prescribed compliance conditions.

GST registration cancellation may be relieved under an extended amnesty scheme for revocation where the registrant falls within the notified period and complies with the prescribed conditions. The article notes that the original revocation scheme under Notification No. 03/2023-Central Tax was extended up to 31.08.2023 by Notification No. 23/2023-Central Tax, and that delay or the availability of an appellate remedy under Section 107 was not treated as a sufficient basis to deny the benefit on the facts discussed. Relief was therefore available in line with the conditions indicated in Tvl. Suguna Cutpiece Centre.

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Issues: Whether the cancellation of GST registration could be interfered with and whether the petitioner was entitled to the benefit of the extended amnesty scheme for revocation of cancellation of registration.

Analysis: The registration was cancelled on 11.07.2023. The Court noted that the amnesty scheme for revocation of cancellation of registration, introduced by Notification No. 03/2023-Central Tax dated 31.03.2023, was extended up to 31.08.2023 by Notification No. 23/2023-Central Tax dated 17.07.2023. It also relied on the earlier decision in M/s. Active Pest Control, which had applied the extended scheme and treated the object of the notifications as enabling revival of cancelled registrations. The objection based on delay and the availability of an appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017 was not accepted as a ground to deny the benefit of the scheme in the facts of the case.

Conclusion: The petitioner was held entitled to relief in view of the extended revocation scheme, subject to compliance with the terms indicated in Tvl. Suguna Cutpiece Centre.

Final Conclusion: The cancellation of registration was not left undisturbed, and the writ petition was allowed on the basis of the extended amnesty framework governing restoration of GST registration.

Ratio Decidendi: Where the Government has extended an amnesty scheme for revocation of cancellation of GST registration, the benefit of that extension can be granted to similarly placed registrants, subject to compliance with the prescribed conditions.

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