Retrospective GST registration cancellation requires a reasoned notice and speaking order; unsupported action cannot stand.

Retrospective GST registration cancellation is sustainable only where statutory preconditions are met and the authority records the factual basis for the action. A show cause notice must disclose the material grounds so the affected taxpayer can make a meaningful response, and the cancellation order must contain reasons. Where the notice is unsupported by facts and the cancellation order is non-speaking, the retrospective cancellation cannot stand. The consequential rejection of revocation also falls once the foundational cancellation is invalid.

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Issues: Whether retrospective cancellation of GST registration could be sustained when the show cause notice did not disclose the factual basis or supporting material and the cancellation order contained no reasons.

Analysis: Retrospective cancellation under the GST law is permissible only where the statutory preconditions exist and the authority records the basis for such action. A show cause notice must set out the material grounds so that the affected person gets a meaningful opportunity to respond. An order cancelling registration retrospectively must also reflect reasons. Where the notice is unsupported by facts and the cancellation order is non-speaking, the action cannot be sustained. The revocation rejection, being consequential, also falls once the foundational cancellation is invalid.

Conclusion: The retrospective cancellation of GST registration was invalid and was set aside, along with the connected rejection of revocation.

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