Facts of the Case
The petitioner, Swamy Moorthi, filed a writ
petition under Article 226 of the Constitution of India before the Madurai
Bench of the Madras High Court challenging the order dated 07.03.2026 issued by
the Commercial Tax Officer, Nagercoil (Rural) Assessment Circle, in Reference
No. ZA3303260386799.
The petitioner sought issuance of a Writ of
Certiorarified Mandamus to call for the records relating to the impugned order,
quash the same as illegal and arbitrary, and direct the respondent to revoke
the cancellation of GST registration bearing GSTIN No. 33BLGPM1164B1ZN.
When the matter came up for hearing, learned
counsel appearing for both sides were ad idem that the controversy was covered
by the earlier judgment of the Court in Tvl. Suguna Cutpiece Center vs The
Appellate Deputy Commissioner (ST) (GST), Salem and Erode, rendered in W.P.
Nos. 25048 of 2021 etc. batch cases.
Issues
Involved
The principal issues arising in the writ petition
were:
- Whether the GST registration cancellation order dated 07.03.2026
was liable to be set aside.
- Whether the petitioner was entitled to revival/restoration of the
cancelled GST registration.
- Whether the matter was fully covered by the earlier judgment in Tvl.
Suguna Cutpiece Center vs The Appellate Deputy Commissioner (ST) (GST),
Salem and Erode.
- Whether revival of GST registration should be made subject to
compliance with conditions relating to filing of pending returns, payment
of tax, interest, fine and fee, and restrictions on utilisation of Input
Tax Credit.
- Whether GST liability for the period subsequent to cancellation was
required to be discharged in cash pending scrutiny and approval of
eligible Input Tax Credit.
Petitioner’s
Arguments
The petitioner challenged the cancellation order
dated 07.03.2026 and sought restoration/revival of GST registration No.
33BLGPM1164B1ZN.
At the hearing, the petitioner’s counsel agreed
that the matter was covered by the judgment in Tvl. Suguna Cutpiece Center
vs The Appellate Deputy Commissioner (ST) (GST), Salem and Erode, involving
restoration of cancelled GST registrations subject to specified compliance
conditions.
Accordingly, the petitioner sought relief on the
same terms and conditions laid down in the said precedent.
Respondent’s
Arguments
The respondent was represented by the learned
Government Advocate.
At the hearing, both learned counsel were ad idem
that the matter was covered by the earlier judgment in Tvl. Suguna Cutpiece
Center vs The Appellate Deputy Commissioner (ST) (GST), Salem and Erode.
Thus, the respondent’s side did not dispute the
applicability of the principles and conditions laid down in the said batch
judgment to the present writ petition.
Court Order
/ Findings
The Madras High Court noted the consensus between
both sides that the matter was covered by the judgment in Tvl. Suguna
Cutpiece Center vs The Appellate Deputy Commissioner (ST) (GST), Salem and
Erode.
The Court reproduced the operative conditions from
paragraph 229 of the said earlier judgment and, in view thereof, passed the
following order:
- The impugned order dated 07.03.2026 was set aside.
- The writ petition was allowed on the same terms and conditions
as extracted from the earlier judgment.
- No costs were awarded.
The conditions governing revival of registration,
as adopted by the Court, include the following:
- The petitioner must file returns for the period prior to
cancellation, where not already filed, together with unpaid tax, interest
for belated payment, and applicable fine and fee for delayed filing,
within 45 days from receipt of the order, if not already paid.
- Tax, interest, fine, fee and related amounts cannot be paid or
adjusted out of unutilised or unclaimed Input Tax Credit lying with the
petitioner.
- Any Input Tax Credit remaining unutilised cannot be utilised until
scrutinised and approved by the appropriate or competent departmental
officer.
- Only approved Input Tax Credit may thereafter be utilised for
discharge of future tax liability under the Act and Rules.
- GST must also be paid and returns filed for the period subsequent
to cancellation by declaring the correct value of supplies, and such GST
payment must be made in cash.
- Input Tax Credit earned during the relevant period may be utilised
only after scrutiny and approval by the respondents or another competent
authority.
- The authorities may impose appropriate restrictions or limitations
to prevent undue passing of Input Tax Credit and to ensure that the relief
is not misused for bill trading.
- Upon payment of tax and penalty and uploading of returns, the
registration shall stand revived forthwith.
- The authorities are required to take suitable steps by instructing
GST Network, New Delhi, to make necessary changes in the GST web portal
architecture to permit filing of returns and payment of tax, penalty and
fine.
- The required exercise must be carried out by the authorities within
30 days from receipt of a copy of the order.
Important
Clarification
This judgment is significant because the High Court
did not grant unconditional restoration of GST registration. The cancellation
order was set aside and relief was granted expressly on the same terms as the
earlier Tvl. Suguna Cutpiece Center judgment.
The order therefore clarifies that revival of
cancelled GST registration remains linked with substantive tax compliance,
including:
- filing of pending returns;
- payment of outstanding tax;
- payment of applicable interest, fine and fee;
- non-adjustment of specified dues against unutilised or unclaimed
ITC;
- scrutiny and approval of ITC before utilisation;
- cash payment of GST for the period subsequent to cancellation;
- prevention of undue passing of ITC and bill trading; and
- necessary GST portal enablement by the authorities.
A particularly important aspect is that, upon
compliance through payment of tax and penalty and uploading of returns, the
registration shall stand revived forthwith in terms of the conditions adopted
by the Court.
Sections
Article 226 of the Constitution of India — Writ jurisdiction of the High Court invoked for issuance of
Certiorarified Mandamus.
GST Registration Cancellation and Revival Framework — The dispute concerns cancellation and consequential revival/restoration of GST registration.
Link to download the order -
https://www.mytaxexpert.co.in/uploads/1783068569_421compressed.pdf
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