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11. The petitioner relies on a decision of the Division Bench of this Court in M/s Elasto Rubber Pvt. Ltd v. The Commissioner of SGST Delhi 7, wherein this Court quashed the cancellation of GST registration. The petitioner states that they have undertaken to settle any tax liabilities accrued or due for the business year 2020 to the present or any charges payable to the respondents.

12. The petitioner further submits that if the respondents retroactively cancel the GST registration effective 23.04.2019, it would invalidate the GST invoices issued during that period and affect the transactions made under that GST number. Consequently, GST officers have been issuing demand notices to purchasers who received GST tax invoices from the petitioner for transactions between 2019 and 2020. The petitioner argues that this is unlawful and unsustainable in law, asserting that the respondents cannot retroactively cancel the firm's registration from 23.04.2019.

19. The petitioner firm submits that it seeks an opportunity to revive its GST registration to regularize the defaults. Reliance is placed on the judgment of the Madras High Court in Tvl. Suguna Cutpiece Center v. The Appellate Deputy Commissioner10, where it was held that cancellation of GST registration serves no useful purpose and contravenes the objectives of the GST regime. The Court observed that excluding taxpayers from the GST framework leads to revenue leakage and undermines the purpose of ensuring proper tax collection on goods and services. Denying the revival of registration 2007 SCC OnLine SC 842 2022 SCC OnLine Mad 8903 W.P.(C) 14279/2024 & Connected Matters KUMAR VATS Signing Date:07.02.2025 15:10:30 effectively isolates entrepreneurs and hinders revenue generation. Therefore, the impugned Show Cause Notice and cancellation order merit being set aside, and the Petitioner's GST registration should be restored.

48. Respondent No. 3 issued a SCN on 23.10.2021 stating "Non- compliance of any specified provisions in the GST Act or the Rules made thereunder as may be prescribed." However, the petitioner asserts that it was unaware of this SCN, as it was not informed by its GST consultant, and consequently, the petitioner was unable to participate in the proceedings. Subsequently, on 18.12.2021, the respondents passed an order cancelling the petitioner's GST registration retrospectively with effect from 01.07.2017. In or around November 2023, the petitioner learned from another GST consultant that it should have initiated the revocation of its GSTIN for Delhi. Upon instructing the GST consultant to undertake the necessary compliance measures, the petitioner was informed that revocation of the Delhi GST registration was not possible, as the GST number had been cancelled retrospectively from 01.07.2017.

52. Upon learning in September 2021 that the GST registration had been cancelled by the Superintendent, the petitioner directed his accountant to visit the GST office to initiate the restoration process. However, the Superintendent informed them that the time to file a reply had lapsed and advised them to file an appeal before the appellate authority for the restoration of the GST registration.