Cancellation of registration quashed and remitted after failure to consider taxpayer's portal reply; fresh hearing ordered

Cancellation of registration was challenged on the ground that the administrative authority did not consider the taxpayer's portal reply and supporting documents, giving rise to a breach of natural justice. The legal basis emphasises requirement to consider explanations submitted in response to a show-cause notice and to provide an opportunity of hearing; failure to record findings on the reply vitiates the impugned action. Consequence: the impugned cancellation is quashed and the matter is remitted for fresh decision after affording the registrant an opportunity of hearing and appropriate consideration of the submitted explanation and documents.

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Issues: Whether the order cancelling the petitioners GST registration dated 12.09.2025 should be quashed and set aside on the ground that the petitioners reply dated 13.08.2025 (filed on the GST Portal) was not considered, warranting remand for fresh decision after providing opportunity of hearing.

Analysis: The petition challenges the cancellation order passed under Section 29 of the Central Goods and Services Tax Act, 2017 pursuant to a show-cause notice issued in Form GST REG-17 and relying upon a confidential communication. The material on record shows that the petitioner filed a reply with supporting documents on 13.08.2025 through the GST Portal. The impugned order does not record any findings addressing or appreciating the explanation and documents furnished by the petitioner. The statutory scheme and procedural fairness require that a reply to a show-cause notice and supporting material must be considered and an opportunity of hearing provided before a decision to cancel registration is finally taken. The absence of any recorded consideration of the petitioners reply vitiates the order and necessitates fresh consideration by the authority. All contentions of the parties were kept open for reconsideration by the authority.

Conclusion: The cancellation order dated 12.09.2025 is quashed and set aside. The matter is remanded to the Superintendent, Range III, Ahmedabad for passing a fresh order after giving the petitioner an opportunity of hearing; fresh order to be passed within 12 weeks. The conclusion is in favour of the assessee.

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