GST registration cancellation upheld where notice and hearing were given, statutory remedies were unused, and delayed writ relief was refused.

GST registration cancellation was upheld where the record showed a show cause notice, an opportunity of hearing, and non-filing of the final return under the CGST Act. The court treated the statutory procedure as complied with, so the challenge based on procedural illegality failed. The writ petition was also held not maintainable because the petitioner did not pursue the available revocation and appeal remedies under the GST framework and approached the court after more than 13 months, indicating acquiescence. Relief under Article 226 was therefore declined.

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Issues: (i) Whether the cancellation of GST registration was vitiated by procedural illegality or ambiguity. (ii) Whether the writ petition was maintainable in view of the statutory remedies available against the cancellation order.

Issue (i): Whether the cancellation of GST registration was vitiated by procedural illegality or ambiguity.

Analysis: The cancellation order was preceded by a show cause notice and an opportunity of hearing. The record showed non-furnishing of the final return under Section 29(2)(c) of the Central Goods and Services Tax Act, 2017, and the petitioner did not respond to the notice or avail the hearing. The statutory procedure under Section 29 of the Central Goods and Services Tax Act, 2017 was therefore treated as complied with.

Conclusion: The cancellation order was not vitiated by procedural illegality, and the challenge on that ground failed.

Issue (ii): Whether the writ petition was maintainable in view of the statutory remedies available against the cancellation order.

Analysis: The remedy of revocation under Section 30 of the Central Goods and Services Tax Act, 2017 and the appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017 were not invoked. The challenge was raised after more than 13 months, supporting acquiescence in the cancellation order and barring recourse to writ jurisdiction.

Conclusion: The writ petition was not maintainable, and the petitioner was not entitled to relief under Article 226 of the Constitution of India.

Final Conclusion: The challenge to cancellation of registration was rejected, and the writ jurisdiction was declined in view of the petitioner's failure to pursue the statutory remedies and the absence of any procedural infirmity.

Ratio Decidendi: Where a cancellation order under the GST regime is preceded by notice and hearing, and statutory remedies of revocation and appeal are not pursued, a delayed writ challenge may be declined on the grounds of procedural compliance, acquiescence, and availability of alternative remedies.

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