GST registration restoration permitted on full statutory payment despite appeal limitation expiring and delayed revocation proceedings.

GST registration cancelled for non-compliance may be restored on terms despite expiry of the statutory appeal limitation where the taxpayer undertakes to clear all outstanding tax, interest, late fee and penalty and the State does not object subject to payment. The notes state that the appellate authority cannot condone delay beyond the outer limit under Section 107 and that revocation or appeal was not pursued within limitation. However, cancellation and appellate orders were set aside, with revival of registration directed upon payment of the quantified statutory liabilities within the stipulated period.

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Issues: Whether cancellation of GST registration and dismissal of the statutory appeal as time-barred warranted interference and restoration of registration upon settlement of outstanding statutory dues.

Analysis: The appellate authority could not condone delay beyond the outer period prescribed under Section 107. The petitioner had also not pursued revocation or appeal within the prescribed limitation. However, the outstanding tax position, the petitioner's willingness to discharge all tax, interest, late fee and penalty, and the absence of objection from the State subject to such payment justified restoration on terms.

Conclusion: The cancellation and appellate orders were set aside, and registration was directed to be revived upon payment of the quantified tax liability, interest, late fee and penalty within the stipulated period.

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