Natural justice in GST registration cancellation requires hearing and reasons; limitation-based rejection cannot sustain a void order.

Cancellation of GST registration must be preceded by a meaningful opportunity of hearing and a reasoned order; where the authority ignores the taxpayer's reply, omits reasons, and proceeds without personal hearing, the action is arbitrary and unsustainable. The text also notes that an appellate rejection based only on limitation cannot preserve a foundational order that is prima facie void and non est. The impugned notices and cancellation orders were therefore quashed, and the matter was remanded for fresh adjudication after granting a personal hearing.

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Issues: Whether the cancellation of GST registration and rejection of revocation were liable to be quashed for breach of natural justice and absence of reasons, and whether the matter required remand for fresh adjudication.

Analysis: The cancellation and rejection orders did not reflect consideration of the petitioner's reply, were passed without affording a personal hearing, and did not contain reasons. In matters involving cancellation of GST registration, which carries serious civil consequences, such an approach is arbitrary and unsustainable. The appellate order rejecting the appeal only on limitation, without examining the merits of the foundational order, was also found to be an unduly pedantic approach where the underlying cancellation itself was prima facie void and non est. The proceedings were therefore required to be reopened and decided afresh after giving the petitioner an opportunity to be heard.

Conclusion: The impugned notices and cancellation orders were quashed and the matter was remanded to the original authority for fresh adjudication after granting a personal hearing.

Ratio Decidendi: An order cancelling GST registration, if passed without a personal hearing and without reasons, is liable to be set aside, and an appellate dismissal on limitation cannot be allowed to sustain a foundational order that is ex facie illegal and non est.

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