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GST registration cancellation must remain confined to the grounds stated in the show-cause notice. Where the notice alleges non-existence at the declared business premises, cancellation cannot instead rest on alleged wrongful availment of input tax credit; cancellation on that distinct, unstated ground is unsustainable and was revoked. Input tax credit liability also cannot be determined through appellate restoration conditions. Any proposed reversal or payment of disputed credit requires a prescribed notice, adjudication and meaningful opportunity to contest. A conditional cash-deposit requirement and automatic-void clause attached to restoration were unsustainable, while fresh proceedings for alleged wrongful credit remained available in accordance with law.
GST registration cancellation must remain confined to the grounds stated in the show-cause notice. Where the notice alleges non-existence at the declared business premises, cancellation cannot instead rest on alleged wrongful availment of input tax credit; cancellation on that distinct, unstated ground is unsustainable and was revoked. Input tax credit liability also cannot be determined through appellate restoration conditions. Any proposed reversal or payment of disputed credit requires a prescribed notice, adjudication and meaningful opportunity to contest. A conditional cash-deposit requirement and automatic-void clause attached to restoration were unsustainable, while fresh proceedings for alleged wrongful credit remained available in accordance with law.
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