Notice-specific grounds for GST registration cancellation required restoration where cancellation relied on unnotified non-filing of consecutive returns.

Cancellation of GST registration cannot rest on non-furnishing of consecutive returns when the show-cause notice alleged only fraudulent registration, invoicing without supply, and non-operation from the declared premises. As non-furnishing of six consecutive returns is a distinct ground under Rule 21(h) of the Central Goods and Services Tax Rules, 2017, relying on it without prior notice denied the registered person an opportunity to respond. The cancellation order and show-cause notice were quashed, GST registration was restored, and a fresh, properly particularised notice may be issued in accordance with law.

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Issues: Whether cancellation of GST registration could be sustained on the ground of non-furnishing of consecutive returns when that ground was not stated in the show-cause notice.

Analysis: The show-cause notice alleged fraudulent registration, issuance of invoices without supply, and non-conduct of business from the declared premises. The cancellation order, however, proceeded on non-furnishing of six consecutive returns, a distinct ground under Rule 21(h) of the Central Goods and Services Tax Rules, 2017. Cancellation on a ground for which no prior notice was given denied the registered person an opportunity to respond to the case proposed against it.

Conclusion: The cancellation founded on an unnotified ground was invalid; the cancellation order and show-cause notice were quashed and the GST registration stood restored, without prejudice to issuance of a fresh, properly particularised notice in accordance with law.

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