Facts of the Case
The Petitioner, M/s. Shree Siddivinayak Publications, is a
Hindu Undivided Family (HUF) managed by its Kartha, Mr. Gopal Agarwal. The
petitioner operates a business engaged in the publishing of newspapers and was
a registered taxable person under the CGST Act, 2017, holding a valid
registration certificate dated February 22, 2018.
The dispute began when the Respondent No. 2 (The
Superintendent of Central Tax, Balanagar Range) issued a statutory Show Cause
Notice (SCN) dated September 2, 2021. The notice called upon the petitioner to
show cause as to why its GST registration should not be cancelled, assigning
the core reason that the petitioner had failed to furnish its statutory returns
for a continuous period of six months.
In response, the petitioner submitted a comprehensive,
detailed written objection on October 3, 2021, detailing its administrative
challenges and business realities. However, without properly considering or
evaluating the objections raised, Respondent No. 2 proceeded to pass an
impugned order dated October 29, 2021, summarily cancelling the petitioner’s
GST registration. Aggrieved by this, the petitioner preferred an appeal before
Respondent No. 1 (The Joint Commissioner, Appeals-II). The First Appellate Authority
rejected the appeal via an Order-in-Appeal dated August 17, 2022, sustaining
the cancellation on the grounds that the petitioner had allegedly collected
taxes from clients without depositing them timely to the exchequer. This forced
the petitioner to move the High Court via a Writ Petition under Article 226.
Issues Involved
- Whether
the action of the tax authorities in cancelling the GST registration of
the petitioner without evaluating or addressing the detailed written
objections submitted in response to the Show Cause Notice violates the
Principles of Natural Justice?
- Whether
the summary confirmation of registration cancellation by the First
Appellate Authority was sustainable when the matter severely, adversely
affected the ongoing lawful business operations of the taxpayer?
- Whether
the case of the petitioner could be resolved by maintaining absolute
parity with prior settled legal precedents of the same jurisdiction,
specifically the ruling in M/s. Chenna Krishnama Charyulu Karampudi v.
Additional Commissioner (Appeals-1).
Petitioner’s Arguments
- Violation
of Natural Justice: The petitioner argued that passing a
summary order of cancellation without dealing with the specific parameters
and explanation provided in their detailed objection dated October 3,
2021, amounts to an administrative action devoid of reasons and a clear
violation of natural justice.
- Severe
Business Hardship: The petitioner pointed out that they
run an active newspaper publication business. The absolute cancellation of
GST registration acts as a "civil death" for the commercial
enterprise, making it impossible to carry out regular economic activities,
thereby infringing upon their fundamental rights under Articles 14 and
19(1)(g) of the Constitution.
- Willingness
to Comply: The petitioner maintained that they did not
intend to evade tax obligations and sought an open platform to fully
submit, regularize, and furnish all pending statutory returns as provided
under the tax laws.
Respondent’s Arguments
- Failure
of Statutory Obligation: The respondents contended
that the taxpayer was continuously carrying out business operations and
collecting taxes from its clients but systematically failed to file
periodical returns and discharge its financial liabilities to the central
exchequer.
- Intent
to Evade Tax: Respondent No. 1 observed that the
explanations provided during personal hearings were completely
insufficient. The authority argued that the petitioner showed an intention
to evade payment of timely dues until the strict cancellation process was
initiated.
- Liability
Safeguarded: The revenue department highlighted that
pursuant to Section 29(3) of the CGST Act, the cancellation order does not
absolve or eliminate the taxpayer's liability to discharge past or pending
tax liabilities, whether determined before or after the cancellation
order.
Court Order / Findings
The division bench of the Hon’ble Chief Justice Ujjal Bhuyan
and Hon’ble Sri Justice C.V. Bhaskar Reddy observed that the core legal issue
raised in the writ petition was no longer res integra (unsettled). The
High Court noted that an identical legal challenge regarding arbitrary
registration cancellation had already been carefully analyzed and resolved by
the same court in several prior writ petitions, most notably in M/s. Chenna
Krishnama Charyulu Karampudi v. Additional Commissioner (Appeals-1) (Writ
Petition No. 27071 of 2022, decided on June 27, 2022).
By maintaining strict judicial discipline and parity with its
earlier rulings, the High Court held that because the cancellation of a GST
registration drastically and adversely affects active business operations, the
taxpayer must be granted a fair, fresh, and real opportunity of being heard.
Consequently, the High Court:
- Set
aside and quashed the Order-in-Appeal dated August 17, 2022, as well as
the original cancellation order dated October 29, 2021.
- Remanded
the entire matter back to Respondent No. 2 (The Superintendent of Central
Tax) for fresh adjudication in accordance with the law.
- Directed
the authority to grant a fresh opportunity of personal hearing to the
petitioner, expressly keeping it open for the petitioner to furnish all
their pending statutory returns during such reassessment proceedings.
Important Clarification
The High Court clearly clarified that while the revenue
authorities must ensure strict tax compliance, the right to run a business
shouldn't be choked by administrative oversights. The court allowed the
taxpayer a curative path by remanding the matter, thereby reinforcing that the
object of Section 29 is to regulate compliance, and if a taxpayer is willing to
step forward, come clean, and furnish all outstanding returns under the
statute, the department must evaluate that option on its merits rather than making
the business shutdown permanent.
Sections Involved
- Section
29 of the Central Goods and Services Tax (CGST) Act, 2017:
Governs the cancellation or suspension of GST registration.
- Section
29(2)(c) of the CGST Act, 2017: Pertains specifically to
the cancellation of registration by the proper officer where a registered
person filing returns under composition levy or normal taxpayer fails to
furnish returns for a continuous period of six months.
- Section
29(3) of the CGST Act, 2017: Explicitly clarifies that
the cancellation of registration does not affect the statutory liability
of a person to pay tax and other dues for any period prior to or after the
date of cancellation.
- Article
226 of the Constitution of India: Invoked to approach the
High Court under its Special Original Jurisdiction seeking a Writ of
Mandamus to set aside the arbitrary orders.
- Articles
14, 19(1)(g), and 21 of the Constitution of India:
Constitutional provisions cited by the petitioner to highlight violations
regarding the right to equality, freedom of trade/business, and right to
life/livelihood.
Link to download the order -https://mytaxexpert.co.in/uploads/1782967999_47compressed.pdf
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