GST registration cancellation notices require specific factual allegations; bare citation of Rule 21 grounds denies meaningful hearing.

A show cause notice proposing cancellation of GST registration must disclose the factual basis and manner of the alleged contraventions under Rule 21. Merely citing Rule 21(b), (e) and (g), without material particulars, prevents the registered person from submitting an effective reply and causes prejudice. Such a mechanically issued notice denies a meaningful opportunity of hearing and is inconsistent with principles of natural justice. A notice lacking the factual basis of the alleged violations is invalid, although fresh proceedings may be initiated through a notice containing the requisite particulars.

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Issues: Whether a show cause notice proposing cancellation of GST registration is valid when it merely cites Rule 21(b), (e) and (g) without disclosing the factual basis of the alleged violations.

Analysis: The notice did not specify the facts or manner constituting the alleged contraventions. A notice issued mechanically, without particulars of the proposed action, prevents the registered person from furnishing an effective reply and causes prejudice. Such absence of material particulars denies a meaningful opportunity of hearing and is inconsistent with principles of natural justice.

Conclusion: A show cause notice lacking the factual basis for alleged violations under Rule 21 is invalid; the authorities may initiate fresh proceedings through a notice containing the requisite particulars.

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