Adjudication Order Set Aside: Service of Notice on Cancelled GST Registration Invalid

By | February 22, 2025

Adjudication Order Set Aside: Service of Notice on Cancelled GST Registration Invalid

Summary in Key Points:

  • Issue: Was the service of the show cause notice valid, given that the assessee’s GST registration had been cancelled retrospectively?

  • Facts: The assessee’s GST registration was cancelled retrospectively. Subsequently, a show cause notice was issued electronically, leading to an adjudication order. The assessee challenged the order, arguing that they were not obligated to check the GST portal due to the cancelled registration.

  • Decision: The court held that since the assessee’s registration was cancelled and not revived, they were not obligated to monitor the GST portal for notices. The service of the show cause notice was deemed invalid, as no physical notice was issued. The adjudication order was set aside, and the assessee was allowed to treat it as a show cause notice and submit a reply.

Important Note: This decision clarifies that notices served electronically on a cancelled GST registration are not valid. The court emphasized the importance of proper service of notice, especially when the assessee’s registration has been cancelled. This ruling protects taxpayers from ex-parte orders and ensures that they are given a fair opportunity to respond to allegations before any adverse action is taken. The decision highlights the need for tax authorities to ensure proper service of notices, even in cases of cancelled registrations, to uphold the principles of natural justice.

HIGH COURT OF ALLAHABAD
Envicon Technologies India (P.) Ltd.
v.
State of U.P.
Arun Bhansali, CJ.
and Vikas Budhwar, J.
WRIT TAX No. – 61 of 2025
JANUARY  10, 2025
Ajay Kumar Kashyap and Ravindra Kumar Rastogi for the Petitioner. Ankur Agarwal, Adv. for the Respondent.
ORDER
1. Having heard Sri Ajay Kumar Kashyap, learned counsel for the petitioner and Sri Ankur Agarwal learned Standing Counsel for the respondents, it remains undisputed that the petitioner’s registration under the UPGST Act, 2017 was cancelled on 4.10.2019 w.e.f. 24.9.2019. It is not the case of the revenue that the said registration has ever been revived or that the petitioner ever sought revival of that registration.
2. In view of the above, it does merit acceptance that the petitioner was not obligated to visit the GST portal to receive the show cause notices that may have been issued to the petitioner for 2018-19 through e-mode, preceding the adjudication order dated 29.04.2024 passed in pursuance thereto.
3. It is also not the case of the revenue that any physical/offline notice was issued to or served on the petitioner before the impugned order came to be passed.
4. In view of peculiar facts noted above, no useful purpose may be served in keeping the petition pending or calling counter affidavit at this stage or to relegate the present petitioner to the forum of alternative remedy.
5. Since essential requirement of rules of natural justice has remained to be fulfilled, we set aside the order dated 29.04.2024. The petitioner may treat the said order itself to be the notice and submit its final reply thereto within a period of four weeks from today. Subject to such compliance by the petitioner, fresh order may be passed after affording opportunity of personal hearing, as expeditiously as possible, preferably within a period of three months therefrom.
6. Writ petition is accordingly disposed of.
Category: GST

About CA Satbir Singh

Chartered Accountant having 12+ years of Experience in Taxation , Finance and GST related matters and can be reached at Email : Taxheal@gmail.com