Recording of reasons and opportunity to controvert are required; orders without reasons and withheld remarks set aside and remanded.

Show cause notice and cancellation order issued under the GST statutory framework were invalid for failing to record reasons, supporting facts, or any application of mind, which deprived the affected taxpayer of a clear factual and legal basis to respond; those orders were quashed. The appellate process breached procedural fairness by obtaining para wise remarks from the assessing officer without furnishing them to the taxpayer for rebuttal despite the taxpayer's appearance; the appellate order was quashed. The matter is remanded for fresh adjudication with an opportunity to file replies and receive a personal hearing, and decisions must record sufficient reasons and afford an opportunity to controvert relied material.

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Issues: (i) Whether the impugned show cause notice in Form GST REG-17 dated 15.04.2025 and the order of cancellation in Form GST REG-19 dated 14.05.2025, issued/passed under Rule 22(1) and Rule 22(3) of the Goods and Services Tax Rules, 2017 read with Section 29(2)(e) of the Goods and Services Tax Act, 2017, are vitiated for want of reasons and findings; (ii) Whether the appellate authority's disposal dated 29.12.2025 violated procedural fairness by obtaining para-wise remarks from the Deputy State Tax Officer and not providing those remarks to the petitioner, thereby denying an opportunity to controvert them.

Issue (i): Whether the show cause notice and order of cancellation were invalid for failure to record reasons and findings.

Analysis: The impugned proceedings only referenced Section 29(2)(e) of the Goods and Services Tax Act, 2017 without attaching supporting materials or recording specific findings on the facts forming the basis for cancellation. The absence of reasons and any application of mind in the notice and the cancellation order deprived the petitioner of a clear factual and legal basis to respond, undermining the procedural requisites inherent in administrative cancellations under the cited provisions and Rules.

Conclusion: The show cause notice dated 15.04.2025 and the cancellation order dated 14.05.2025 are set aside for failure to record reasons and findings and for non-application of mind.

Issue (ii): Whether the appellate authority's procedure in seeking para-wise remarks and not furnishing them to the petitioner denied a fair opportunity of hearing.

Analysis: The appellate authority obtained para-wise remarks from the Deputy State Tax Officer and proceeded without furnishing those remarks to the petitioner for rebuttal, despite the petitioner's appearance. This procedure denied the petitioner an opportunity to controvert material relied upon at the appellate stage and breached the requirement of fair hearing in adjudicatory and appellate processes under the GST framework.

Conclusion: The appellate order dated 29.12.2025 is set aside for violation of procedural fairness by not providing the petitioner an opportunity to controvert the para-wise remarks obtained from the assessing officer.

Final Conclusion: The show cause notice, the cancellation order and the appellate order are quashed and the matter is remanded to the proper officer for fresh adjudication in accordance with law with an opportunity to submit reply and for personal hearing; the writ petition is disposed of.

Ratio Decidendi: Administrative orders of cancellation under Section 29(2)(e) of the Goods and Services Tax Act, 2017 and Rules 22(1) and 22(3) of the Goods and Services Tax Rules, 2017 must record sufficient reasons and findings and afford the affected person an opportunity to receive and controvert material relied upon, failing which the orders are liable to be set aside and remanded for fresh decision.

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