Retrospective GST registration cancellation quashed; respondents must reconsider the notice under conditional revival and compliance directions.

The petition contests a show cause notice proposing retrospective cancellation of the petitioner's GST registration from 01.07.2017; the court reviewed the legality of retrospective cancellation under constitutional judicial review and applied the principles and directions in Tvl.Suguna Cut Piece Center regarding quashing and conditional revival. The court quashed the portion of the notice proposing cancellation from 01.07.2017 and directed respondents to re-decide the show cause notice in accordance with those directions, including conditional revival, filing of returns, payment of tax/interest/penalty, and controlled scrutiny and utilisation of input tax credit.

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Issues: Whether the impugned Show Cause Notice in Form GST Reg-17 dated 27.02.2026, which proposes cancellation of the petitioner's GST registration with effect from 01.07.2017, is sustainable and whether relief should be granted to the petitioner.

Analysis: The petition challenges a notice proposing cancellation of GST registration effective from 01.07.2017, issued after inspection (13.11.2025), recording of statement under Section 67 of the Tamil Nadu Goods and Services Tax Act, 2017 (14.11.2025) and a related demand (DRC-01A dated 18.02.2026). The Court disposed the petition at admission with consent and examined the legality of proposing retrospective cancellation from 01.07.2017. The Court applied the principles of Article 226 of the Constitution of India and followed the guidelines and conditions set out by this Court in Tvl.Suguna Cut Piece Center (paras 227-229) relating to quashing of cancellation orders, conditional revival of registration, filing of returns, payment of tax/interest/penalty, and scrutiny and controlled utilisation of input tax credit.

Conclusion: The portion of the Show Cause Notice that proposes cancellation of the petitioner's GST registration with effect from 01.07.2017 is quashed. The respondents are directed to pass orders on the show cause notice in accordance with the directions issued in Tvl.Suguna Cut Piece Center (including conditional revival, filing of returns, payment of tax/interest/penalty, and controlled scrutiny/use of input tax credit).

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