GST registration cancellation challenge requires disclosure of relied-on material and fair reconsideration of revocation proceedings.

When GST registration cancellation is challenged and a revocation application is pending, the affected taxpayer must be supplied the inspection material and connected correspondence relied upon by the department. The revocation request must then be reconsidered after giving an effective opportunity to file a supplementary reply, and the pending show cause notice must be adjudicated on merits after considering the reply already filed. The writ petition was disposed of with these procedural directions to ensure fair reconsideration of the cancellation and related tax proceedings.

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Issues: Whether the petitioner was entitled to a direction for supply of the inspection material and for consideration of the application seeking revocation of cancellation of GST registration, along with adjudication of the pending show cause notice.

Analysis: The cancellation of registration had been challenged after the petitioner filed a revocation application. The records referred to inspection material and related correspondence that had not been furnished to the petitioner. In these circumstances, the petitioner was required to be supplied the material gathered during inspection and the connected documents, and the revocation application had to be considered after giving the petitioner an opportunity to supplement the reply. The pending proposal under the show cause notice was also required to be adjudicated on merits after considering the reply already filed.

Conclusion: The petitioner obtained a direction for disclosure of the relevant material and for consideration of the revocation application and the pending tax notice, after hearing the petitioner.

Final Conclusion: The writ petition was disposed of by issuing procedural directions that enabled reconsideration of the cancellation and adjudication of the pending tax proceedings.

Ratio Decidendi: When cancellation of GST registration is under challenge and a revocation application is pending, the affected person must be furnished the material relied upon and given an effective opportunity before the application and connected proceedings are decided.

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