Facts of the Case
The petitioner, M/s Rohit Kumar, is an individual earning
his livelihood as a registered Government Contractor. The GST Department issued
an order dated January 21, 2022, canceling the petitioner's GST registration.
Aggrieved by this sudden and detrimental cancellation, which directly disrupted
his business operations and livelihood, the petitioner moved the Hon’ble High
Court of Uttarakhand by filing a Writ Petition (WPMS No. 2718 of 2022) seeking
a writ to call for the records and quash the cancellation order.
Issues Involved
- Whether
the cancellation of the petitioner's GST registration solely due to
non-compliance with Rule 10A (failure to update bank details) warrants
absolute termination of registration without providing an alternative
administrative remedy for revocation.
- Whether
a petitioner can be directed to approach the proper State Tax Officer for
the redressal of grievances and restoration of GST registration upon
correcting technical defaults and clearing outstandings, in the absence of
an active or accessible appellate forum.
Petitioner’s Arguments
The petitioner, represented by learned counsel Shri Ashish
Agarwal and Shri Tarun Pandey, argued that the cancellation of his GST
registration had severely impacted his capability to execute government
contracts, thereby violating his fundamental right to carry on trade and
business. It was contended that the procedural lapse of not updating bank
details under Rule 10A was a rectifiable defect rather than a fraudulent
evasion of tax. Therefore, an absolute cancellation was disproportionate, and
the registration ought to be restored to allow him to continue his livelihood
and complete his compliance procedures.
Respondent’s Arguments
The respondents, represented by Shri Mohit Maulekhi, learned
Brief Holder for the State of Uttarakhand, strongly supported the department's
initial action. It was submitted that the petitioner's GST registration was
cancelled entirely due to non-compliance with Rule 10A of the G.S.T. Rules,
as the petitioner had failed to update his mandatory bank account details on
the GST portal.
However, the State's counsel fairly submitted that while the
petitioner had been given an initial opportunity to appear before the Assistant
Commissioner (Sales Tax), the standard appellate forum was currently not
available for this specific grievance. Consequently, the respondent suggested
that the petitioner could directly approach the localized State Tax Officer for
the redressal of his grievances.
Court Findings and Order
The matter was heard before the Single Bench of Hon’ble
Shri Sanjaya Kumar Mishra, J.. Taking into consideration the submissions of
both parties and the lack of an immediate appellate forum, the Hon’ble High
Court disposed of the writ petition with the following directions:
- Liberty
to Approach the Officer: The Court granted clear
liberty to the petitioner to physically or formally appear before the State
Tax Officer, Haldwani.
- Rectification
of Defects: The petitioner was directed to remove all
technical defects pointed out by the GST Department, specifically the
updating of bank details under Rule 10A.
- Clearance
of Liabilities: The petitioner must clear all outstanding
tax dues, interest, or penalties standing against him.
- Favorable
Consideration for Revocation: The Court explicitly
ordered that upon the petitioner fulfilling these conditions (defect
removal and payment of dues), his prayer for the revocation of the
order of cancellation of GST registration shall be considered favorably
by the department.
- The
Court further ordered the grant of an urgent certified copy of the order
to the parties as per the rules.
Important Clarification
This judgment clarifies that procedural non-compliance—such
as failing to upload bank details under Rule 10A—should not permanently strip a
taxpayer of their registration if they are willing to rectify the defect. When
alternative appellate remedies are bottlenecked or unavailable, taxpayers can
approach the High Court under Article 226 to seek a practical pathway toward compliance
and registration restoration, provided they clear their outstanding tax dues.
Section Involved
- Rule
10A of the Central Goods and Services Tax (CGST) / Uttarakhand Goods and
Services Tax (UKGST) Rules, 2017: Failure to furnish
information relating to bank account details within the prescribed time
limit after the grant of registration.
- Section
30 of the CGST / SGST Act, 2017: Revocation of
cancellation of registration.
- Article 226 of the Constitution of India: Power of High Courts to issue certain writs.
Link to download the order -https://mytaxexpert.co.in/uploads/1783315705_926compressed.pdf
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