Defective GST cancellation notice lacking particulars was set aside; precise allegations are required before adverse action.

A show cause notice proposing cancellation of GST registration was unsustainable because it merely reproduced Rule 21(b) of the CGST Rules, 2017 without identifying any invoice, bill, or transaction said to involve supply without goods or services. A valid notice must set out the precise factual allegations so the noticee can respond meaningfully to the proposed adverse action. Where the notice lacks concrete particulars and does not disclose the factual basis of the charge, it fails the requirements of lawful notice. The notice was set aside and GST registration was directed to be restored.

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Issues: Whether the show cause notice proposing cancellation of GST registration, which merely reproduced Rule 21(b) of the Central Goods and Services Tax Rules, 2017 without specifying any invoice, bill, or transaction, was liable to be set aside.

Analysis: The notice did not disclose any concrete basis for the proposed cancellation and failed to identify the particular invoice or bill alleged to have been issued without supply of goods or services. A show cause notice must enable the noticee to answer the precise allegations forming the foundation of adverse action. Where the notice is bereft of particulars and does not indicate the factual basis of the allegation, it does not satisfy the requirements of a valid notice.

Conclusion: The notice was held to be unsustainable and was set aside, with a direction to restore the GST registration.

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