Restoration of GST registration permitted where registrant shows genuine noncompliance and agrees to file returns and pay dues.

Quashing the rejection of a belated appeal and revoking cancellation of GST registration is appropriate where the registrant demonstrates genuine reasons for non filing and offers to regularize compliance; the registrant must file outstanding returns and pay tax, interest, fees and penalties within the prescribed period, and restoration is granted subject to conditions protecting revenue. Conditions include departmental scrutiny and approval before any utilization of input tax credit and other safeguards to prevent improper adjustment or benefit pending verification; the order preserves the authority to impose restrictions while permitting conditional reinstatement.

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Issues: Whether the cancellation of GST registration and the rejection of the appeal on the ground of limitation can be quashed and the GST registration restored subject to conditions where the registrant was unable to file returns for a period due to genuine health and financial difficulties and is willing to file returns and pay tax, interest and penalties.

Analysis: The factual matrix shows cancellation of GST registration followed by a belated appeal rejected on limitation grounds; the petitioner attributes non-filing to health and financial problems and seeks restoration conditioned on filing returns and payment of dues. The court examined whether equitable relief in the form of quashing the rejection and revoking the cancellation is appropriate where the registrant offers to regularize compliance by filing outstanding returns and discharging tax liabilities with interest and fees. The court also considered safeguards relating to input tax credit to prevent improper adjustment or utilization pending departmental scrutiny and approval.

Conclusion: The appeal rejection order is quashed and the cancellation of GST registration is revoked; restoration is granted subject to conditions requiring the registrant to file outstanding returns and pay tax, interest, fees and penalties within the specified period, and subject to restrictions on utilization of input tax credit until departmental scrutiny and approval.

Ratio Decidendi: Where a registrant demonstrates genuine reasons for non-compliance and offers to regularize returns and pay dues, a court may quash a cancellation and conditional rejection on limitation to permit restoration while imposing conditions to protect revenue including scrutiny and approval before utilization of input tax credit.

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