Natural justice requires GST cancellation notices to disclose factual particulars; a cryptic notice cannot sustain consequential cancellation.

A show cause notice for GST registration cancellation must disclose the essential factual basis of the alleged breach so the taxpayer can meet the case against it. A notice that merely reproduces statutory violations without material particulars is cryptic and violates natural justice. Because the cancellation order rested on the same deficient notice, the defect in the foundation vitiated the consequential action, and both the notice and cancellation order were set aside, with liberty to proceed afresh in accordance with law.

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Issues: Whether the show cause notice and the consequential cancellation of GST registration were liable to be set aside for want of factual particulars and violation of principles of natural justice.

Analysis: The notice merely reproduced alleged violations of the Act and Rules without disclosing the factual foundation on which those allegations were made. A taxpayer is entitled to know the precise case to meet, and a notice that does not contain the basic reasons or material particulars prevents an effective reply. Since the final cancellation order was founded on the same cryptic notice, the defect in the foundation vitiated the consequential action as well.

Conclusion: The show cause notice and the consequential cancellation order were held unsustainable and were set aside. The respondents were left at liberty to proceed afresh in accordance with law.

Ratio Decidendi: A show cause notice initiating adverse action must disclose the essential factual basis of the alleged breach; a cryptic notice lacking such particulars violates natural justice and cannot sustain consequential proceedings.

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