GST registration cancellation notice must state specific allegations; bare reproduction of Rule 21(b) is unsustainable.

A show cause notice proposing cancellation of GST registration must set out a clear factual basis and identify the specific invoice, bill or transaction alleged to be in breach; a notice that merely reproduces Rule 21(b) without particulars does not enable an effective reply and is legally unsustainable. On that footing, the notice was set aside and the suspension of registration was revoked with restoration of GST registration, while leaving the proper officer free to start fresh proceedings in accordance with law if warranted.

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Issues: Whether a show cause notice proposing cancellation of GST registration, which merely reproduces Rule 21(b) of the Central Goods and Services Tax Rules, 2017 without specifying the invoice, bill, or transaction alleged to be in breach, is legally sustainable and whether the consequent suspension of registration can be maintained.

Analysis: The impugned notice did not disclose any specific factual basis for the proposed cancellation. It only repeated the text of Rule 21(b) without identifying the particular invoice or bill said to have been issued without supply of goods or services, and without enclosing any material that would indicate the precise allegation. A show cause notice must enable the noticee to answer the adverse case made against it; where no concrete allegation is set out, the notice fails to serve that function and becomes meaningless.

Conclusion: The show cause notice was held unsustainable and was set aside. The suspension of GST registration was directed to be revoked and the registration restored forthwith, while leaving it open to the proper officer to initiate fresh proceedings in accordance with law if warranted.

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