Statutory appellate remedy governs factual GST cancellation challenges, while pre-deposit cannot be waived without express legal authority.

Challenges to GST registration cancellation alleging inadequate notice or hearing should ordinarily proceed through the statutory appellate remedy when the record shows that a show-cause notice, reply opportunity, and personal hearing were available. Questions about whether those opportunities were adequate are factual matters for the Appellate Authority to examine. A writ challenge should not bypass that effective appellate framework on those facts. Statutory pre-deposit is mandatory unless the applicable law contains an enabling provision for exemption; where no such provision exists, the requirement cannot be waived. The statutory appeal remains available for examination of the factual natural justice challenge.

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Issues: (i) Whether the challenge to cancellation of GST registration and alleged denial of natural justice should be entertained in writ jurisdiction despite an available statutory appeal; (ii) Whether exemption from the statutory pre-deposit requirement could be granted.

Issue (i): Whether the challenge to cancellation of GST registration and alleged denial of natural justice should be entertained in writ jurisdiction despite an available statutory appeal.

Analysis: The record showed that a show-cause notice, opportunity to file a reply, and personal hearing had been afforded, but were not availed. The sufficiency of the opportunity and the asserted breach of natural justice involved factual questions appropriately examinable by the Appellate Authority under the statutory appellate framework.

Conclusion: The challenge was relegated to the statutory appellate remedy, against the assessee.

Issue (ii): Whether exemption from the statutory pre-deposit requirement could be granted.

Analysis: No enabling provision under the applicable statute permitted an exemption from the pre-deposit requirement.

Conclusion: Exemption from statutory pre-deposit was unavailable, against the assessee.

Final Conclusion: The petitioner may pursue the statutory appeal, in which the factual challenge concerning adequacy of opportunity can be considered.

Ratio Decidendi: A writ challenge involving factual questions about adequacy of notice and hearing should ordinarily be pursued before the statutory appellate authority where an effective appeal is available; statutory pre-deposit cannot be waived absent enabling authority.

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