Sujoy Paul Vs Union of India And Ors. (Gauhati High Court)
The petitioner, a registered assessee under the Central Goods and Services Tax Act, 2017 and the State Goods and Services Tax Act, 2017, challenged an order dated 16.03.2026 rejecting his application for revocation of cancellation of GST registration.
A Show Cause Notice dated 07.07.2025 was issued under Rule 22(1)/(2A) of the CGST Rules alleging failure to furnish returns for a continuous period of six months. The notice did not specify the relevant period of default. As the notice uploaded on the common portal escaped the petitioner’s attention, no reply was filed. Thereafter, on 19.11.2025, the Proper Officer cancelled the petitioner’s GST registration under Section 29 of the CGST Act read with Rule 22(3) of the CGST Rules in Form GST REG-19, recording “others” as the reason for cancellation, with effect from 19.11.2025.
After learning of the cancellation order, the petitioner updated GST returns up to November 2025 through the GST portal and filed an application for revocation of cancellation in Form GST REG-21 on 11.02.2026 under Rule 23(1), stating that all GST returns had been filed and updated. In response, the Proper Officer issued a Show Cause Notice dated 27.02.2026 in Form GST REG-23 stating that the application was liable to be rejected as all Government dues had not been paid and directing the petitioner to submit proof of payment of late fees for GSTR-1 and interest, if any, within seven working days.
