ORDER :

MAUNA M. BHATT, J.

1. This petition under Article 226 of the Constitution of India is preferred with the prayer to quash and set aside the showcause notice dated 26.05.2022, as also the order of cancellation of registration dated 11.10.2022.

2. The briefly stated facts:

2.1 The petitioners engaged in the business of trading in bullion, were duly registered under the provisions of Central/Gujarat Goods and Services Tax Act, 2017 (hereinafter referred to as “the Act”). It is case of the petitioners that sale and purchase of goods is their usual course of business and all their transactions were duly reflected in the returns filed. The taxes were duly paid as per the returns filed. All the transactions of the petitioners were duly supported by tax invoices and all the payments were made through banking channels. A search proceeding was carried out by the Central GST Department at the premises of the petitioners on 08.12.2021. On the allegation of wrongful availment of Input Tax Credit (ITC) under the GST Act to avoid coercive action, the petitioners reversed ITC of Rs.90,00,000/- and further made payment of Rs.2,00,00,000/- through electronic cash ledger under protest to show thei