Facts of the
Case
The petitioner, Gaurav, filed a writ petition
challenging the order dated 10.06.2025 passed by the GST authorities whereby
his GST registration was cancelled retrospectively with effect from 19.10.2023.
A Show Cause Notice dated 20.09.2024 had been issued alleging that the
registration was liable to be cancelled under Section 29(2)(e) of the CGST Act
on the ground that the registration had been obtained by fraud, wilful
misstatement or suppression of facts, and alleging excess availment of Input
Tax Credit.
The petitioner submitted a reply to the Show Cause
Notice explaining the ITC position. However, the impugned cancellation order
did not properly deal with the explanation offered by the petitioner and
ordered retrospective cancellation of registration.
Issues
Involved
Whether retrospective cancellation of GST
registration under Section 29 of the CGST Act was sustainable without recording
specific reasons, whether the cancellation order reflected due application of
mind to the petitioner’s reply, and whether such retrospective cancellation
could be sustained in law.
Petitioner’s
Arguments
The petitioner contended that the cancellation
order was unreasoned and mechanical, that the explanation regarding alleged
excess ITC was not considered, and that retrospective cancellation of
registration had serious civil consequences. Reliance was placed on settled
judicial precedents holding that retrospective cancellation under Section 29
cannot be exercised routinely or without recording cogent reasons.
Respondent’s
Arguments
The GST Department relied on the Show Cause Notice
issued to the petitioner and submitted that cancellation was justified on
account of alleged excess availment of ITC and non-genuine conduct. It was
contended that the authority was empowered under Section 29 of the CGST Act to
cancel registration, including with retrospective effect.
Court Order
/ Findings
The Delhi High Court examined the impugned order
and found that the same failed to properly consider the petitioner’s
explanation with respect to alleged excess ITC. The Court observed that
retrospective cancellation of GST registration is not sustainable unless the
order itself reflects due application of mind and records reasons justifying
such retrospective effect.
Relying on earlier decisions including Ridhi Sidhi
Enterprises v. Commissioner of Goods & Service Tax, Ramesh Chander v.
Assistant Commissioner of GST, and Delhi Polymers v. Commissioner, Trade and
Taxes, the Court reiterated that although Section 29(2) empowers retrospective
cancellation, such power cannot be exercised mechanically or routinely and must
be supported by objective reasons.
The Court held that the impugned order suffered
from an abject failure to assign even rudimentary reasons for retrospective
cancellation and was therefore unsustainable in law.
Important
Clarification
The High Court clarified that retrospective
cancellation of GST registration has serious consequences, including denial of
ITC to recipients, and therefore requires a reasoned order demonstrating due
application of mind. Mere existence of statutory power under Section 29 is not
sufficient to justify its retrospective invocation.
Final
Outcome
The writ petition filed by Gaurav was allowed.
The order dated 10.06.2025 cancelling GST registration with retrospective
effect was set aside. The matter was remanded to the Adjudicating
Authority with directions to grant the petitioner a personal hearing,
consider the reply and submissions, and thereafter pass a reasoned order in
accordance with law. All rights and remedies of the parties were kept open,
and pending applications were disposed of accordingly.
Source
Link- https://delhihighcourt.nic.in/app/showFileJudgment/PMS11092025CW140222025_112219.pdf
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