GST registration restoration follows return filing and payment compliance where cancellation rests solely on continuous non-filing of returns.

GST registration cancelled solely for continuous non-filing of returns may be restored where the registered person completes return-filing and payment obligations. The note states that, absent allegations of a dubious tax-evasion process, continued cancellation prevents business operations and invoice issuance and may hinder determination and recovery of tax liability. Cancellation was therefore set aside conditionally, with restoration dependent on filing all returns for the default period and paying the consequential tax, interest, fine and penalty within the stipulated period.

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Issues: Whether cancellation of GST registration for continuous non-filing of returns should be set aside and registration restored upon compliance with return-filing and payment obligations.

Analysis: The cancellation was founded solely on non-filing of returns, without any allegation of a dubious process for tax evasion. Continued cancellation would prevent the registered person from conducting business and issuing invoices, thereby impairing determination and recovery of the tax liability. A pragmatic course was therefore warranted, consistent with the requirement that outstanding returns be filed and consequential tax, interest, fine and penalty be paid.

Conclusion: The cancellation order was set aside conditionally; registration is to be restored if the petitioner files all default-period returns and pays the requisite tax, interest, fine and penalty within the stipulated period.

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