Material particulars in show cause notices: lack of specific tax period, invoices or suppliers vitiated cancellation and revocation orders.

The HC found the show-cause notice legally deficient for failing to disclose material particulars (tax period, invoices, suppliers, quantification), preventing a meaningful response and violating principles of natural justice, and therefore set it aside. The cancellation order was quashed for being mechanically dictated by an investigative request without independent application of mind to satisfy jurisdictional facts under the statutory scheme. The rejection of revocation was held non speaking and pre determined because it reproduced investigative conclusions without independent reasoning addressing the statutory threshold, so registration was restored and fresh proceedings ordered with a detailed notice and opportunity to respond.

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Issues: (i) Whether the show-cause notice dated 10.09.2025 was vitiated by vagueness and non-disclosure of material particulars; (ii) Whether the order dated 25.08.2025 cancelling GST registration was passed under dictation and without independent exercise of quasi-judicial power; (iii) Whether the order dated 31.10.2025 rejecting the application for revocation was a non-speaking order reflecting pre-determination.

Issue (i): Whether the show-cause notice dated 10.09.2025 was vitiated by vagueness and non-disclosure of material particulars.

Analysis: The notice merely recited statutory language alleging availing of input tax credit in violation of Section 16 of the Central Goods and Services Tax Act, 2017 without specifying tax period, invoices, suppliers or quantification. Section 16 and Rule 21(e) require that a notice enabling meaningful response must disclose the material facts forming the basis of proposed action. The absence of particulars prevented effective response and undermined the requirements of due notice and principles of natural justice.

Conclusion: Issue (i) decided in favour of the assessee.

Issue (ii): Whether the order dated 25.08.2025 cancelling GST registration was passed under dictation and without independent exercise of quasi-judicial power.

Analysis: The sequence shows an investigative request dated 08.08.2025 preceding the cancellation order, with no record of independent evaluation or reasoned satisfaction by the authority under Section 29 of the Central Goods and Services Tax Act, 2017 read with Rule 21(e) of the Central Goods and Services Tax Rules, 2017. Quasi-judicial power must be exercised on the basis of independent application of mind and objective satisfaction of jurisdictional facts; subordination to an investigative dictum indicates mechanical exercise of power and imperils constitutional and statutory safeguards.

Conclusion: Issue (ii) decided in favour of the assessee.

Issue (iii): Whether the order dated 31.10.2025 rejecting the application for revocation was a non-speaking order reflecting pre-determination.

Analysis: The purported show-cause on revocation and the final rejection reproduced the interim investigative findings verbatim, declaring liability to reject while inviting explanation. There was no independent reasoning addressing whether the alleged discrepancy met the statutory threshold under Section 16(2) or warranted cancellation under Rule 21(e). Such repetition of investigative conclusions without reasoning amounts to a non-speaking order and indicates pre-determination.

Conclusion: Issue (iii) decided in favour of the assessee.

Final Conclusion: The impugned show-cause notice, cancellation order and order rejecting revocation are set aside; registration is to be restored and fresh proceedings, if any, must comply with statutory requirements by issuing a detailed notice and affording a reasonable opportunity to respond.

Ratio Decidendi: A quasi-judicial authority exercising power to cancel GST registration must independently apply its mind and issue a detailed notice disclosing material particulars (tax period, invoices, suppliers, quantification) so as to afford meaningful opportunity of hearing; mechanical reliance on an investigative directive or issuance of non-speaking orders reflecting pre-determination vitiates the exercise of such power.

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