IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Date of decision: 01.04.2026 M/s AMC Trade Link .....Petitioner Versus State of Punjab and others .....Respondents CORAM : HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Sandeep Goyal, Senior Advocate with Mr. Rishab Singla, Advocate for the petitioner.

Mr. Saurabh Kapoor, Addl. A. G., Punjab.

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DEEPAK SIBAL, J. (Oral (1) The respondent - revenue authorities served upon the petitioner a notice dated 14.01.2026 requiring the petitioner to show cause as to why its GST registration be not cancelled. To the said show cause notice, the petitioner filed replies/additional replies dated 27.01.2026, 19.02.2026 and 20.02.2026. On 20.02.2026, at 12:00 noon, the petitioner received another notice, through registered post, through which the petitioner was informed that the earlier notice sent to the petitioner dated 14.01.2026 be treated as a notice as to why its GST registration may not be cancelled retrospectively. At 07:00 p.m. on the same day i.e. 20.02.2026, the impugned order was passed cancelling the petitioner’s GST registration with retrospective effect.

(2) Through this petition the petitioner challenges order dated 20.02.2026 cancelling its GST registration with retrospective effect on the ground that the initial notice served upon the petitioner dated 14.01.2026 did not put the petitioner to notice that its GST registration was sought to be cancelled retrospectively and that the subsequent notice dated 17.02.2026, physically received by the petitioner through registered post on 20.02.2026, at 12:00 noon, through which the petitioner was, for the first time, put to notice that its GST registration was sought to be retrospectively cancelled, did not grant the petitioner adequate time to respond in terms of Rule 22 of the Central Goods and Services Tax Rules, 2017 (for short – the 2017 Rules). In support of its case, learned counsel for the petitioner places reliance on a Division Bench judgment of this Court dated 20.02.2026 passed in CWP No.16770 of 2024 – M/s Bansal Casting Vs. Union of India and another (3) Learned State counsel, who appears on advance notice, submitted that in addition to the aforesaid two notices dated 14.01.2026 and 17.02.2026, the petitioner was also sent an e-mail dated 17.02.2026 through which the petitioner was also put to notice that its GST registration is sought to be cancelled retrospectively and therefore, the petitioner’s claim that the impugned order dated 20.02.2026 is in violation of principles of natural justice is misconceived.

(4) Learned counsel for the parties have been heard.

(5) In M/s Bansal Casting’s case (supra) a Division Bench of this Court held as under :-

“13. Undoubtedly, there is a provision for retrospective cancellation of registration in terms of Section 29 of CGST Act, subject to the provisions as contained therein. It is apposite to note that while such power of retrospective cancellation of registration is definitely conferred, it is apparent that such action can be taken only upon existence of specific contingencies and that an order under Section 29(2) of CGST Act must definitely reflect the reasons for such cancellation with retrospective effect. Furthermore, it is a basic, accepted and settled principle that concerned authority is enjoined upon to put the assessee to notice of the action which is intended to be taken and reasons or the premise on which such action is sought to be taken. Hon'ble the Supreme Court in ORYX Fisheries Pvt. Ltd. Vs.

Union of India and others, 2010(13) SCC 427, has held as under:-

"24. It is well settled that a quasi-judicial authority, while acting in exercise of its statutory power must act fairly and must act with an open mind while initiating a show cause proceeding. A show cause proceeding is meant to give the person proceeded against a reasonable opportunity of making his objection against the proposed charges indicated in the notice.

14. Thus a show caus