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Issues: Whether the orders cancelling and refusing to revoke GST registration were liable to be quashed for want of reasons and breach of natural justice, and whether the consequential proceedings could be set aside with a remand for fresh decision.
Analysis: The cancellation and revocation orders did not disclose reasons for the adverse action. The Court treated the requirement of recording reasons as a settled legal necessity in such matters and held that an assessee must be afforded a fair opportunity of hearing before registration is cancelled. Since the impugned orders were non-speaking and the challenge arose in the context of GST registration cancellation, the appropriate course was to set aside the orders, undo the consequential notice, and remit the matter for fresh adjudication after issuing a fresh notice and granting personal hearing.
Conclusion: The cancellation and revocation orders were quashed, the consequential notice was also set aside, and the matter was remanded for fresh consideration with opportunity of hearing.
Final Conclusion: The petitioner obtained substantive relief against the impugned cancellation process, but the tax authority was left free to proceed afresh in accordance with law after following due process.
Ratio Decidendi: An order cancelling GST registration must be a reasoned and speaking order passed after granting a meaningful opportunity of hearing, and a non-speaking cancellation order is liable to be set aside with remand for fresh adjudication.