Restoration of GST registration is available on filing pending returns and paying tax, interest and late fee, prompting dropping of cancellation.

Cancellation of GST registration for non-filing of returns for six continuous months engages the proviso to Rule 22(4), under which restoration is available if the person furnishes all pending returns and makes full payment of tax dues with applicable interest and late fee; upon such compliance the cancellation proceedings must be dropped and the prescribed order passed. The proper officer has jurisdiction to consider a restoration application filed within the stipulated period and must do so expeditiously. The decision also addresses computation of limitation for recovery proceedings, treating the limitation period as running from the court order date where applicable.

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Issues: Whether a person whose GST registration has been cancelled under Section 29(2)(c) of the Central Goods and Services Tax Act, 2017 for non-filing of returns for six continuous months can seek restoration of registration by furnishing all pending returns and making full payment of tax dues with interest and late fee as provided in the proviso to sub-rule (4) of Rule 22 of the Central Goods and Services Tax Rules, 2017, and whether the appropriate authority is obliged to consider such an application filed within a limited time.

Analysis: The statutory framework permits cancellation of registration where returns have not been furnished for a continuous period of six months (Section 29(2)(c) of the Central Goods and Services Tax Act, 2017) and prescribes the procedural notice and reply mechanism under Rule 22 of the Central Goods and Services Tax Rules, 2017. The proviso to sub-rule (4) of Rule 22(4) provides that if, instead of replying to the show cause notice, the person furnishes all pending returns and makes full payment of tax dues along with applicable interest and late fee, the proceedings shall be dropped and an order in the prescribed form passed. The impugned cancellation therefore engages the proviso; restoration under that proviso requires submission of pending returns and payment of dues. The order also addresses computation of limitation for recovery proceedings, indicating that the period under Section 73(10) is to be computed from the date of the court order, with the financial year 2025-26 addressed as per Section 44 of the Act.

Conclusion: The petitioner is entitled to seek restoration of GST registration by approaching the proper officer within the stipulated period, furnishing all pending returns and making full payment of tax dues with applicable interest and late fee, whereupon the authority has jurisdiction to consider and, if the conditions of the proviso to Rule 22(4) are met, drop the cancellation proceedings and pass the prescribed order. The authority shall consider such application expeditiously within the time directed by the Court.

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