Defective show-cause notice and natural justice breach led to GST registration cancellation being set aside and restored.

A GST registration cancellation based on allegations of wilful misstatement and suppression of facts was set aside because the show-cause notice did not disclose the specific factual basis needed for an effective reply. A notice that only cites legal provisions, without supporting particulars, fails to provide a reasonable opportunity of defence and breaches natural justice. The cancellation order was therefore unsustainable, and the registration was restored, while the authority remained free to issue a fresh show-cause notice in accordance with law.

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Issues: Whether the order cancelling GST registration was liable to be set aside on the ground that the show-cause notice was defective and did not disclose the specific allegations required to enable an effective defence.

Analysis: The cancellation order rested on allegations of wilful misstatement and suppression of facts, but the show-cause notice did not set out those allegations with supporting particulars. A notice that merely refers to legal provisions without furnishing the factual foundation of the proposed action does not afford a reasonable opportunity to reply. In such circumstances, the affected person is prejudiced and the action is vitiated for breach of the principles of natural justice. The challenge was treated as covered by the earlier decision relied on by the petitioner.

Conclusion: The cancellation order was unsustainable and was set aside. The GST registration stood restored, and the authority was left free to issue a fresh show-cause notice in accordance with law.

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