GST registration revocation remains unavailable where tax liability is quantified, pending payment or final resolution of the liability challenge.

Rejection of revocation of cancelled GST registration was not considered open to interference because the departmental record showed that tax liability had already been quantified. The premise that no quantified liability existed was therefore factually incorrect. The taxpayer may challenge the tax-quantification order through available remedies and may subsequently seek revocation of registration after payment of tax or once that challenge attains finality, in accordance with law.

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Issues: Whether the rejection of the application for revocation of cancellation of GST registration warranted interference when the tax liability had subsequently been quantified.

Analysis: The departmental record established that an order quantifying the tax liability had been passed under Section 74. The factual premise that no quantified liability existed was therefore incorrect. The petitioner sought liberty to pursue challenge against that order and to seek revocation after payment of tax or after finality of such challenge.

Conclusion: No interference with the rejection order was warranted; the petitioner could pursue the available legal remedies and thereafter seek revocation in accordance with law.

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