DEEPAK SIBAL, J. (Oral)

Through show cause notice dated 03.02.2026, the petitioner was put to notice as to why its GST registration be not cancelled to which the petitioner filed a written response along with supporting documents. Thereafter, through order dated 03.03.2026, the petitioner’s GST registration has been cancelled which order has been challenged through the instant petition.

Learned counsel for the petitioner submits that in response to the show cause notice dated 03.02.2026 the petitioner had filed a detailed written response along with necessary evidence which has been rejected through the impugned adjudication order by simply stating therein that the petitioner’s reply to the show cause notice has been examined.

Learned State counsel defends the impugned adjudication order by simply stating that the petitioner’s reply filed to the show cause notice was duly considered and an opinion was formed by the Proper Officer on the basis whereof the petitioner’s registration was rightly ordered to be cancelled.

Learned counsel for the parties have been heard.

The show cause notice dated 03.02.2026 issued to the petitioner and the impugned cancellation order dated 03.03.2026 are reproduced hereinafter for ready reference:-

Show Cause Notice For Cancellation Of Registration

FORM GST REG-17 (See Rule 22(1)]

Reference No.: ZA0302260035329 Date: 03/02/2026

To

Registration Number (GSTIN/UIN): 03AAUFN9251C1Z6

NEELKANTH ENTERPRISES

TEHSIL KHANNAH B NO 221, Alaur, Ludhiana, Punjab, 141401

Show Cause Notice for Cancellation of Registration

Whereas on the basis of information which has come to my notice, it appears that your registration is liable to be cancelled for the following reasons:

1. Rule 21(a) - Person does not conduct any business from declared place of business/place of business not found

2. Rule 21(b)- person issues invoice or bill without supply of goods or services or both in violation of the provisions of the Act, or the rules made thereunder

3. Rule 21(d)-person violates the provision of rule 10A (Bank details)

4. Rule 21 (e)-person avails ITC in violation of the provisions of section 16 of the Act or the rules made thereunder

5. Rule 21(g)-person violates the provision of rule 86B

Remarks:

During physical verification of Principal place of Business, the taxpayer was found to be non-traceable/non existent. Further, on verification of the record available at portal, major L1/L2 suppliers of the taxpayer were found to be cancelled/suspended suo-moto by the department. It appears that the Noticee had availed ineligible ITC from these suspicious suppliers whose regn. had already been cancelled as on date and details of some of these cancelled major suppliers (as on date) whose regn. was cancelled retrospectively due to their involvement in suspicious activities of passing/receiving of fake/bogus ITC, is as under: -

(i) 07CHJPJ8476R1Z8 (cancelled w.e.f. 09.05.2025)

(ii) 07AVJPK2380B1ZU (cancelled w.e.f. 14.01.2025)

(ii) 07CGHPA6664F1ZG (cancelled w.e.f. 17.03.2025)

(iv) 07MZBPS3001D1ZM (cancelled w.e.f. 28.04.2025)

etc.

In view of above facts, it appears that retrospective cancellation of registration is warranted:

-To prevent misuse of Input Tax Credit (ITC) through fictitious invoicing,

-To break the fraudulent ITC chain,

-To nullify GSTINs obtained through misrepresentation, and

-To safeguard government revenue from non-compliant and non-existent taxpayers.

In view of above facts, it is requested to pay the above said amount alongwith applicable interest & penalty, failure which your regn. will be cancelled with retrospective effect.

You are also requested to appear for Personal Hearing (PH) on the given date and time, along with documents e.g. tax paid challan in form of DRC-03 against above said amount, documents in respect of establishing the existence of the unit at the