Condonation of delay under Odisha GST revocation rules allows conditional consideration of registration restoration after dues and formalities are met.

Delay in invoking the proviso to Rule 23 of the Odisha GST Rules may be condoned where the taxpayer undertakes to clear tax, interest, late fee, penalty and other dues and comply with the prescribed formalities. On that basis, the revocation application for cancellation of registration is to be considered in accordance with law, while safeguarding revenue interests through conditional compliance. The writ challenge to cancellation was therefore not decided on merits, and the taxpayer obtained only a conditional opportunity to seek restoration of registration.

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Issues: Whether delay in invoking the proviso to Rule 23 of the Odisha Goods and Services Tax Rules could be condoned and the petitioner's application for revocation of cancellation of registration directed to be considered upon deposit of tax dues and compliance with other formalities.

Analysis: The writ petition challenged cancellation of registration under the Odisha Goods and Services Tax Act, 2017. The petitioner expressed readiness to deposit tax, interest, late fee, penalty and other dues, and relied on an earlier coordinate Bench order where delay in invoking the proviso to Rule 23 of the Odisha Goods and Services Tax Rules was condoned and the revocation application was directed to be considered in accordance with law on compliance with the prescribed conditions. Following the same course, identical relief was extended, the Court treating the matter as one where revenue interests could be safeguarded by insisting on payment and compliance.

Conclusion: The delay was condoned and the petitioner was granted relief, with the revocation application to be considered upon deposit of the dues and compliance with the required formalities.

Final Conclusion: The cancellation-related challenge was not rejected on merits, and the petitioner obtained a conditional opportunity to seek restoration of registration in accordance with law.

Ratio Decidendi: Delay in invoking the proviso to Rule 23 of the Odisha Goods and Services Tax Rules may be condoned where the taxpayer undertakes to clear the dues and comply with the required formalities, enabling consideration of revocation in accordance with law.

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