GST registration cancellation set aside, with revocation to be considered after filing pending returns and paying costs.

GST registration cancellation and the appellate rejection were set aside, with the Court holding that the absence of hearing was not established because a show cause notice had been issued. The dispute was nevertheless resolved on the taxpayer's willingness to regularise past defaults and re-enter compliance. The petitioner was directed to file the pending GST returns and pay costs, and upon such compliance the authority was to consider revocation of registration.

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Issues: Whether the orders cancelling the GST registration and rejecting the appeal were liable to be set aside, and whether the petitioner could be permitted to revive registration by filing pending returns and paying costs.

Analysis: A show cause notice had been issued before cancellation of registration, and the appellate order had rejected the appeal on the ground of delay. On the facts, the Court found that the grievance of absence of opportunity of hearing was not made out. At the same time, the petitioner expressed willingness to regularise the defaults and re-enter the tax regime. In those circumstances, the Court treated the dispute as one warranting restoration into the regular tax system, subject to compliance with the pending return-filing obligation and payment of costs.

Conclusion: The cancellation order and the appellate order were set aside. The petitioner was directed to file the pending GST returns and pay costs of Rs. 50,000, and upon such compliance the authority was to consider revocation of registration.

Ratio Decidendi: In a case of GST registration cancellation, where the taxpayer seeks to regularise past defaults and return to compliance, the Court may set aside the cancellation and permit consideration of revocation upon filing pending returns and payment of costs, even though prior notice had been issued.

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