Conditional restoration of GST registration was granted where non-filing was non-deliberate and outstanding dues were to be paid.

Cancellation of GST registration for non-filing of returns for six months was considered liable to be interfered with where the record did not show fraudulent conduct and the default was treated as non-deliberate. The assessee's willingness to clear outstanding tax, interest, late fee and penalty supported restoration of registration on payment-linked conditions. On that basis, conditional relief was granted and the GST registration was revived subject to compliance with the stipulated dues.

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Issues: Whether the cancellation of the petitioner's GST registration was liable to be interfered with and the registration restored, subject to payment of outstanding GST dues, interest, late fee and penalty.

Analysis: The cancellation had been made for non-filing of GST returns for a continuous period of six months under Rule 22(1) of the Central Goods and Services Tax Rules, 2017. The material on record did not disclose any fraudulent conduct, and the default was treated as non-deliberate. The petitioner expressed readiness to clear the outstanding tax liability together with applicable interest and consequential dues. In these circumstances, restoration of registration on payment of the quantified dues was considered appropriate and beneficial to both sides.

Conclusion: The cancellation was interfered with and the petitioner was granted restoration of GST registration upon compliance with the stipulated payment conditions. The petition succeeded conditionally in favour of the assessee.

Final Conclusion: Conditional relief was granted to revive the GST registration, with the matter finally disposed of through a payment-linked mechanism.

Ratio Decidendi: Where cancellation of GST registration arises from non-deliberate default in filing returns and the taxpayer undertakes to clear all outstanding dues, restoration may be ordered subject to payment of the quantified tax, interest and incidental statutory dues.

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