Reasoned GST registration cancellation is mandatory; procedural defects can justify quashing despite delayed writ filing.

GST registration cancellation must comply with the CGST notice-and-order procedure, with the authority giving clear notice of the default period, an opportunity to respond, and a reasoned speaking order in the prescribed form. Because cancellation carries adverse civil consequences, a bare reference to the statutory ground without recorded reasons was treated as procedurally defective and unsustainable. A delayed writ approach did not defeat relief where the cancellation order itself was legally infirm and affected the taxpayer's ability to carry on business. The impugned cancellation was quashed, the matter was remitted to the show-cause stage, and the taxpayer was allowed to respond and regularise compliance.

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Issues: (i) Whether the GST cancellation order was liable to be set aside for want of reasons and non-compliance with the prescribed procedure; (ii) Whether the petitioner's delayed approach to the writ court disentitled it to relief.

Issue (i): Whether the GST cancellation order was liable to be set aside for want of reasons and non-compliance with the prescribed procedure.

Analysis: Cancellation of registration under the CGST framework is governed by Section 29(2)(c) of the Central Goods and Services Tax Act, 2017 and Rule 22 of the Central Goods and Services Tax Rules, 2017, which require notice, opportunity to reply, and an order in the prescribed form. The notice did not specify the relevant period of default with clarity, and the cancellation order merely referred to the statutory ground without recording reasons. Since cancellation of registration carries adverse civil consequences, the authority was bound to pass a speaking order reflecting application of mind and compliance with the prescribed form and procedure.

Conclusion: The cancellation order was unsustainable and was rightly set aside and quashed in favour of the petitioner.

Issue (ii): Whether the petitioner's delayed approach to the writ court disentitled it to relief.

Analysis: Although the writ petition was filed after a substantial lapse of time, the Court treated the statutory illegality in the cancellation order as more serious than the delay. The absence of reasons and the resulting procedural infirmity were held to outweigh the delay, especially where the impugned order affected the petitioner's ability to carry on business.

Conclusion: Delay did not bar relief.

Final Conclusion: The impugned cancellation order was quashed, the matter was sent back to the stage of the show-cause notice, and the petitioner was given liberty to respond or regularize pending compliance in accordance with the CGST procedure.

Ratio Decidendi: An order cancelling GST registration, which entails adverse civil consequences, must be a reasoned and speaking order passed in conformity with the prescribed statutory procedure and principles of natural justice; otherwise, it is liable to be quashed even if the noticee did not file a reply.

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