Condonation of delay in GST revocation restored conditional consideration of registration upon dues and compliance.

Delay in approaching the revocation authority under the Odisha GST revocation framework was condoned where the assessee was willing to clear statutory dues and comply with prescribed formalities. Applying the earlier coordinate bench approach under the proviso to Rule 23, the court directed consideration of the restoration request on merits subject to deposit of tax, interest, late fee and penalty, together with compliance with other requirements. The relief was treated as consistent with the interest of revenue, and the petitioner was granted the same conditional opportunity to seek revival of registration in accordance with law.

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Issues: Whether the delay in approaching the authority under the revocation framework could be condoned and the petitioner be granted liberty to seek restoration of registration on compliance with tax dues and related formalities.

Analysis: The relief sought was considered on the basis of the earlier coordinate bench order, which had condoned delay under the proviso to Rule 23 of the Odisha Goods and Services Tax Rules and directed consideration of the revocation application subject to deposit of taxes, interest, late fee, penalty, and compliance with other formalities. The same course was applied here, with the court recording that the petitioner was ready to clear the dues and that the relief would operate in the interest of revenue.

Conclusion: The delay was condoned and the petitioner was granted the same conditional relief for consideration of revocation in accordance with law.

Ratio Decidendi: Where the assessee is willing to discharge statutory dues and comply with prescribed formalities, delay in invoking the revocation remedy may be condoned and the application may be directed to be considered on merits in the interest of revenue.

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