Facts of the Case
The petitioner, Globe Coal Company, challenged the appellate order dated
11.03.2025 which upheld cancellation of its GST registration with retrospective
effect from 21.07.2020. The original cancellation order dated 17.08.2023 arose
from a show cause notice dated 11.11.2021 alleging that the petitioner was
non-functional at its principal place of business. The petitioner contended
that the business premises at U-158, Vikas Marg, Shakarpur, East Delhi belonged
to it and that retrospective cancellation jeopardised valid input tax credit
availed during the intervening period.
Issues Involved
Whether GST registration could be cancelled retrospectively when the
show cause notice did not propose such retrospective cancellation, whether
absence of reasons vitiates a retrospective cancellation order, and whether
restoration of registration was warranted to safeguard accrued input tax
credit.
Petitioner’s Arguments
The petitioner submitted that the show cause notice did not contemplate
retrospective cancellation and therefore the cancellation order extending
retrospectively was without jurisdiction. It was argued that the premises
existed and was owned by the petitioner and that retrospective cancellation
would unjustly prejudice the petitioner and its customers by denying valid
input tax credit. The petitioner also sought restoration of registration to
continue business operations.
Respondent’s Arguments
The Department contended that the registration was cancelled on the
ground that the petitioner was found to be non-existent or non-functional at
the declared place of business and defended the cancellation order passed by
the proper officer.
Court Order / Findings
The Delhi High Court held that the settled legal position does not
permit retrospective cancellation of GST registration unless the show cause
notice specifically proposes such action and the order records cogent reasons
justifying retrospective effect. Relying on its earlier decisions including
Riddhi Siddhi Enterprises, Ramesh Chander, and Delhi Polymers, the Court held
that retrospective cancellation has serious civil consequences and cannot be
ordered mechanically. The Court found that neither the show cause notice nor
the cancellation order disclosed reasons warranting retrospective cancellation.
Consequently, the appellate order dismissing the appeal on limitation was also
held to be unsustainable.
Important Clarification
The Court clarified that while retrospective cancellation was
impermissible in the present case, the Department was at liberty to conduct
fresh inspection to verify existence of the petitioner and to proceed in
accordance with law if any violations were found. Restoration of registration
was made subject to filing of pending returns along with applicable late fees
and penalties.
Final Outcome
The writ petition was allowed. The cancellation order dated 17.08.2023
and the appellate order dated 11.03.2025 were set aside. The GST registration
of the petitioner was restored, access to the GST portal was directed to be
provided, and the petitioner was permitted to file pending returns. The
Department was granted liberty to conduct verification and take action in
accordance with law, if required.
Source
Link- https://delhihighcourt.nic.in/app/showFileJudgment/PMS04122025CW72072025_182653.pdf
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