Reasoned Decision Requirement: cancellation lacked reasons and appellate dismissal quashed for fresh hearing and review.

The petition challenges cancellation of GST registration for absence of reasons and application of mind; the court held that quasi judicial administrative orders affecting statutory entitlements must record reasons and show application of mind, and set aside the cancellation for lack of reasons. The appeal was dismissed by the appellate authority as time barred, but the court ruled that where the original order was ex parte and denied opportunity of hearing, an appellate dismissal on limitation alone cannot stand; the appellate order was quashed and the matter remitted for fresh consideration after hearing.

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Issues: (i) Whether the order dated 03.07.2024 cancelling the petitioner's GST registration under Section 29(2)(d) was vitiated for want of reasons and application of mind; (ii) Whether the appellate order dated 22.08.2025 dismissing the appeal as time-barred could sustain where the original order was passed without affording opportunity of hearing.

Issue (i): Whether the cancellation order dated 03.07.2024 is invalid for lack of reasons and absence of application of mind.

Analysis: The impugned cancellation order contains no reasons explaining the basis for taking the harsh step of cancelling registration. The authorities relied on precedents establishing that quasi judicial or administrative orders affecting fundamental rights and statutory entitlements must disclose reasons and reflect application of mind. An order devoid of reasons does not satisfy the requirement of reasoned decision-making and fails the test of equality before law.

Conclusion: The cancellation order dated 03.07.2024 is set aside as it is without application of mind and lacks reasons; conclusion is in favour of the assessee.

Issue (ii): Whether the appellate order dated 22.08.2025 dismissing the appeal as barred by limitation is sustainable in view of the defect in the original order and denial of hearing.

Analysis: The appellate authority dismissed the appeal on limitation grounds. However, because the original order was passed without affording the petitioner an opportunity of hearing and was ex parte, the appellate dismissal cannot sustain in isolation; the court followed coordinate decisions holding that where the original order is vitiated by absence of reasons and denial of hearing, the appellate disposal that does not adjudicate merits is consequential and may be quashed to enable fresh consideration after hearing.

Conclusion: The appellate order dated 22.08.2025 is quashed; conclusion is in favour of the assessee.

Final Conclusion: Both the impugned cancellation order and the appellate order are quashed and set aside, and the matter is remitted for fresh consideration after affording the petitioner an opportunity to file reply and be heard.

Ratio Decidendi: A quasi judicial administrative order affecting statutory registration must record reasons and demonstrate application of mind; absence of reasons and denial of opportunity of hearing render such an order unsustainable and justify quashing and remand for fresh decision after hearing.

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