Delayed GST registration revocation may be allowed on equitable terms when the taxpayer seeks to regularise compliance.

Delayed revocation of cancelled GST registration may be permitted on equitable terms where cancellation for non-filing of returns has serious civil consequences and the assessee seeks to regularise compliance. The Court considered the statutory revocation mechanism, the compliance obligations under the GST framework, and the special procedure introduced for certain cases, and allowed the petitioner to file a revocation application beyond the prescribed period. The permission was made conditional on filing within 30 days and on payment of quantified interest and other statutory penalty or fine, while the dispute over interest was left open for separate challenge.

---

---

Issues: Whether the petitioner could be permitted to file an application for revocation of cancellation of GST registration under section 30 of the Central Goods and Services Tax Act, 2017 beyond the prescribed time, and whether such permission could be made conditional upon payment of the outstanding interest and statutory dues.

Analysis: The registration had been cancelled for non-filing of returns, and the statutory window for revocation had expired. The Court noted that the GST regime contemplates compliance obligations under sections 39 and 45, and that section 30 provides a mechanism for revocation of cancellation. The Court also took account of the notification issued under section 148 creating a special procedure for revocation in certain cases. Emphasising the serious civil consequences of cancellation and the need for a liberal approach where the assessee seeks to regularise the default and continue business, the Court held that the petitioner should not be denied an opportunity solely because the limitation period had expired.

Conclusion: The petitioner was permitted to file an application under section 30 within 30 days from the date of the order, subject to payment of the quantified interest amount and other statutory penalty or fine, and the dispute regarding interest was left open for challenge in separate proceedings.

Final Conclusion: The writ petition succeeded to the extent that a delayed revocation application was allowed to be made on compliance with the conditions imposed by the Court.

Ratio Decidendi: Where cancellation of GST registration carries serious civil consequences and the assessee seeks to regularise compliance, the Court may permit a delayed revocation application under section 30 on equitable terms consistent with the statutory framework.

---