Unreasoned GST registration cancellation violates fairness and Article 14; limitation-based appeal dismissal does not cure the defect.

Cancellation of GST registration was liable to be set aside where the order recorded no reasons, because a quasi-judicial or administrative action affecting business rights must disclose reasons to meet fairness requirements and Article 14. The appellate dismissal as time-barred did not cure the defect or create merger, since it was not a decision on merits. The authority was required to proceed after notice and an opportunity of hearing, including consideration of the assessee's defence and revocation rights. The cancellation order was quashed and the matter was remitted for fresh consideration in accordance with law.

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Issues: Whether cancellation of GST registration was liable to be quashed for want of reasons and whether the appellate dismissal on limitation altered the challenge to the original cancellation order.

Analysis: The cancellation order recorded no reasons for taking the drastic step of cancelling registration. A quasi-judicial or administrative order affecting business rights must disclose reasons, since reasons are essential to satisfy the requirement of fairness and the mandate of Article 14 of the Constitution of India. The dismissal of the appeal as time-barred did not result in merger on the facts of the case, as the appellate order was not a decision on merits. The statutory scheme also contemplates notice and an opportunity to seek revocation, and the authority was required to proceed after considering the assessee's defence.

Conclusion: The cancellation order was invalid and was quashed. The matter was directed to be reconsidered afresh after giving the assessee an opportunity of hearing.

Final Conclusion: The petitioner obtained relief against the cancellation of registration, and the matter was sent back for fresh adjudication in accordance with law.

Ratio Decidendi: A quasi-judicial order cancelling GST registration must contain reasons and comply with fairness requirements; an unreasoned cancellation order is liable to be set aside, and a dismissal of the appeal on limitation does not cure the defect where the appeal is not decided on merits.

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