GST

High Court Rulings under GST Strengthen Due Process and Protect Bona-Fide Buyers: Key Judgments on Section 74, ITC Denial, SCN Defects and Registration Cancellation

December 15, 2025
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No Evidence of Fraud: Allahabad High Court Quashes Section 74 Demand and Restores Buyer’s ITC

Saniya Traders vs. Additional Commissioner Grade-II & Another

Allahabad High Court | WRIT TAX No. 1743 of 2024 | Order dated 03 December 2025

1. Background of the Case

The petitioner, Saniya Traders, is a registered GST dealer engaged in the business of supply of plastic scrap, polymer scrap, and related waste materials.

For the tax period June 2021 (FY 2021-22), the petitioner purchased old scrap batteries from Mohan Enterprises, Muzaffarpur (Bihar) on 28 June 2021, supported by:

  • Tax Invoice No. ME-28/2021-22
  • E-Way Bill No. 821164498832 dated 28.06.2021
  • Payment of IGST through banking channels

The transaction was:

  • Reported by the supplier in GSTR-1
  • Reflected in the petitioner’s GSTR-2A
  • Tax duly paid by the supplier through GSTR-3B under Section 49 of the CGST Act, 2017

2. Initiation of Proceedings under Section 74

Based on an inspection report by the Joint Commissioner, State Tax, Central Investigation Bureau, Bihar, alleging that certain suppliers in the supply chain were non-existent or fictitious, the department issued a notice to the petitioner.

Despite a detailed reply explaining:

  • Supplier was registered at the time of transaction
  • Returns were duly filed
  • Tax was actually deposited with the Government

the department passed an order under Section 74 of the CGST Act, 2017, alleging fraudulent availment of ITC and raising a demand of:

ParticularsAmount (₹)
IGST4,17,997
Interest1,06,589
Penalty4,17,997
Total Demand9,42,584

The statutory appeal was dismissed without proper appreciation of records, leading to the present writ petition.

3. Legal Issue before the High Court

Whether proceedings under Section 74 of the CGST Act, 2017 can be sustained against a bona-fide purchasing dealer, when:

  • The supplier was registered on the date of transaction
  • Tax was actually paid to the Government
  • There was no evidence of fraud, wilful misstatement, or suppression on the part of the buyer

4. Statutory Provisions Involved

Section 74 – CGST Act, 2017

Applicable only when ITC is wrongly availed or utilised by reason of:

  • Fraud
  • Wilful misstatement
  • Suppression of facts

Section 16(2) – CGST Act, 2017

ITC is admissible when:

  • Supplier is registered
  • Tax has been paid to the Government
  • Invoice is valid
  • Returns are filed

5. Arguments of the Petitioner

The petitioner contended that:

  • The supplier was registered at the time of supply
  • GSTR-1 and GSTR-3B were filed by the supplier
  • Tax stood deposited with the Government
  • Payments were made through banking channels
  • GSTR-2A auto-generated, confirming tax payment visibility to the buyer

It was argued that once tax payment is established, Section 16 stands fully complied with, and Section 74 cannot be invoked in absence of fraud.

6. Arguments of the Revenue

The department argued that:

  • Actual movement of goods was not proved
  • Burden lies on the buyer to establish genuineness
  • Relied upon State of Karnataka vs. Ecom Gill Coffee Trading Pvt. Ltd. (SC, 2023)

7. Findings of the Allahabad High Court

The High Court categorically rejected the department’s approach and recorded the following findings:

  • The supplier was registered on the date of transaction
  • Tax was deposited and not disputed by the department
  • GSTR-1, GSTR-3B and GSTR-2A were available on record
  • Authorities ignored auto-populated statutory returns
  • No material established fraud or collusion by the petitioner

The Court observed that mere subsequent cancellation of supplier’s registration cannot invalidate ITC of a bona-fide purchaser.

8. Key Judicial Precedents Relied Upon

The Court relied on and reaffirmed the following landmark rulings:

  1. Commissioner Trade & Tax, Delhi vs. Shakti Kiran India Pvt. Ltd.
    (Supreme Court, decided on 09.10.2025)
    ➤ If supplier was registered at the time of transaction, ITC cannot be denied later.
  2. Solvi Enterprises vs. Additional Commissioner Grade-II
    (2025) 29 Centax 22 (All.)
    ➤ Section 74 requires proof of fraud or wilful misstatement.
  3. Khurja Scrap Trading Company vs. Additional Commissioner Grade-II
    ➤ Bona-fide buyers cannot be penalised for supplier’s later default.
  4. Safecon Lifescience Pvt. Ltd. vs. Additional Commissioner Grade-II
    (Allahabad High Court)
    ➤ ITC denial without evidence of buyer’s fault is unsustainable.

9. Distinguishing Revenue’s Case Law

The Court held that reliance on Ecom Gill Coffee Trading Pvt. Ltd. was misplaced, as:

  • In the present case, all statutory documents were available
  • Tax payment was undisputed
  • There was no allegation of fake invoices by the buyer

10. Final Decision of the Court

The Allahabad High Court held that:

  • Section 74 was wrongly invoked
  • No evidence of fraud or suppression existed
  • ITC was legitimately availed
  • Demand, interest, and penalty were unsustainable

👉 The impugned orders dated 20.12.2022 and 05.02.2024 were quashed, and the writ petition was allowed in favour of the petitioner.

11. Practical Takeaways for GST Professionals

✔ Section 74 cannot be invoked mechanically
✔ Actual tax payment is the decisive factor
✔ GSTR-2A / 3B cannot be ignored by authorities
✔ Buyer cannot be punished for supplier’s later cancellation
✔ Fraud must be specifically alleged and proved

Conclusion

This judgment reinforces a consistent judicial view that bona-fide purchasers are entitled to ITC when statutory compliance is established. Arbitrary invocation of Section 74 without evidence of fraud is illegal and liable to be struck down.

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GST Cancellation Order Set Aside for Using Wrong Form and Granting Only 7 Days to Reply: Gauhati High Court

**Shobnam Ara Begom Mazumder @ Sabnamara Begum Mazumder

vs.
Union of India & Others**

Gauhati High Court | WP(C) No. 6789 of 202
Decision Date: 05 December 2025

1. Brief Facts of the Case

The petitioner, Shobnam Ara Begom Mazumder, was granted GST registration under the CGST Act, 2017 for running a goatery business. The registration certificate was issued in Form GST REG-06 on 13.06.2023 in accordance with Rule 10(1) of the CGST Rules, 2017.

On 10.06.2024, the Proper Officer issued a Show Cause Notice (SCN) proposing cancellation of GST registration, alleging violation of:

  • Rule 10A (non-furnishing of bank account details), read with
  • Rule 21(d) of the CGST Rules, 2017

The SCN:

  • Allowed only 7 days to submit a reply
  • Fixed a hearing on 17.06.2024
  • Suspended the GST registration with immediate effect

2. Cancellation Order and Portal Difficulties

As the SCN was only uploaded on the GST portal and not individually communicated, it escaped the petitioner’s notice.

Subsequently, on 04.07.2024, the department passed an order cancelling GST registration, recording that:

  • No reply was filed
  • Violation of Rule 10A was established
  • Registration stood cancelled with effect from 04.07.2024

After cancellation:

  • The petitioner attempted to upload bank details in Form GST REG-14
  • Also attempted to apply for revocation of cancellation
  • However, the GST portal rejected the application citing limitation expiry

Aggrieved, the petitioner approached the Gauhati High Court under Article 226.

3. Statutory Framework Involved

Rule 10A – CGST Rules, 2017

Requires a registered person to furnish bank account details within 30 days of grant of registration.

Rule 21(d) – CGST Rules, 2017

Provides that registration is liable to be cancelled for violation of Rule 10A.

Rule 21A(2A) – CGST Rules, 2017

Mandates that:

  • In case of contravention of Rule 10A,
  • Registration shall be suspended
  • The registered person must be intimated in Form GST REG-31
  • A 30-day period must be given to explain why registration should not be cancelled

4. Core Legal Issues Before the High Court

  1. Whether a Show Cause Notice in Form GST REG-17 is valid for violation of Rule 10A
  2. Whether granting only 7 days instead of 30 days violates statutory provisions
  3. Whether cancellation without following Rule 21A(2A) violates principles of natural justice

5. Findings of the Gauhati High Court

The High Court found multiple procedural and statutory violations, and held as follows:

(a) Wrong Statutory Form Used

  • For violation of Rule 10A, the SCN must be issued in Form GST REG-31
  • Issuance of SCN in Form GST REG-17 was contrary to Rule 21A(2A)

(b) Illegal Curtailment of Time

  • The statute mandates a 30-day period to respond
  • Granting only 7 days was a clear breach of statutory rules
  • The authorities did not even wait for 30 days before passing the cancellation order

(c) Violation of Natural Justice

  • Failure to provide adequate time amounted to denial of reasonable opportunity
  • Suspension and cancellation were done mechanically and hastily

6. Legal Principle Reaffirmed

The Court reiterated the settled principle of law:

“When a statute prescribes a manner for doing a thing, it must be done in that manner alone and in no other manner.”

Deviation from the prescribed procedure renders the action illegal and unsustainable.

7. Final Decision of the Court

The Gauhati High Court held that:

  • The Show Cause Notice dated 10.06.2024 was invalid
  • The cancellation order dated 04.07.2024 was unsustainable
  • Both were set aside and quashed

The respondents were directed to restore the petitioner’s GST registration with effect from 13.06.2023.

The writ petition was allowed, with no order as to costs.

8. Practical Takeaways for GST Professionals

✔ Cancellation for Rule 10A violation must follow Rule 21A(2A)
✔ Form GST REG-31 is mandatory, REG-17 cannot be substituted
✔ 30 days’ time is statutory, not discretionary
✔ Portal-based notices alone may not satisfy fairness
✔ Mechanical cancellations are vulnerable to judicial review

Conclusion

This judgment is a strong reminder that GST registration cannot be cancelled casually or mechanically. Strict adherence to prescribed forms, timelines, and natural justice is mandatory, and any deviation can render the entire cancellation proceedings void.

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Final GST Demand Cannot Exceed SCN Amounts: Jammu & Kashmir High Court Quashes Demand for Statutory Breach

**Ukas Goods Carrier

vs.
Union Territory of Jammu & Kashmir & Others**

Jammu and Kashmir High Court | WP (C) No. 1961 of 2021
Decision Date: 02 December 2025

1. Brief Background of the Case

The petitioner, M/s Ukas Goods Carrier, is engaged in the business of Goods Transport Agency (GTA) services. The petitioner approached the Jammu and Kashmir High Court under Article 226 of the Constitution of India, challenging:

  • Show Cause Notice dated 06.02.2021, and
  • Final Demand Order dated 26.08.2021,

issued under Section 74 of the Goods and Services Tax Act, 2017.

The challenge was primarily on the ground that the final GST demand exceeded the amount specified in the Show Cause Notice (SCN), in clear violation of Section 75(7) of the GST Act, 2017.

2. Grounds Raised by the Petitioner

The petitioner assailed the impugned proceedings on two principal grounds:

(a) Lack of Jurisdiction – GTA under Reverse Charge

It was contended that:

  • GTA services are covered under Reverse Charge Mechanism (RCM)
  • As per Section 9(3) read with Section 2(98) of the GST Act, 2017, the recipient of service, and not the GTA, is liable to pay tax
  • Therefore, no direct tax liability could be fastened upon the petitioner

(b) Demand Beyond Show Cause Notice

The petitioner further contended that:

  • The SCN under Section 74(1) proposed a demand of ₹4,59,50,000
  • However, the final order under Section 74(9) confirmed a demand of ₹7,61,80,000
  • This was expressly barred by Section 75(7) of the GST Act, 2017

3. Stand of the Revenue

The respondents argued that:

  • The writ petition was not maintainable due to availability of an alternative statutory remedy of appeal under Section 107
  • The petitioner was not only providing GTA services but was also allegedly involved in intra-State and inter-State supply of goods

However, the revenue failed to justify how a demand exceeding the SCN amount could be legally sustained.

4. Core Legal Issue Before the High Court

Whether a final GST demand order passed under Section 74(9) can exceed the amount specified in the Show Cause Notice issued under Section 74(1), in view of Section 75(7) of the GST Act, 2017?

5. Relevant Statutory Provisions

Section 74(1) – GST Act, 2017

Where tax has not been paid or short paid by reason of fraud, wilful misstatement or suppression of facts, the proper officer shall serve a notice requiring the person to show cause why he should not pay the amount specified in the notice, along with interest and penalty.

Section 74(9) – GST Act, 2017

Empowers the proper officer to pass a final adjudication order after considering the reply to the SCN.

Section 75(7) – GST Act, 2017

“The amount of tax, interest and penalty demanded in the order shall not be in excess of the amount specified in the notice and no demand shall be confirmed on the grounds other than the grounds specified in the notice.”

6. Findings of the Jammu & Kashmir High Court

The High Court made the following crucial observations:

  • The SCN specified a demand of ₹4.59 crore
  • The final order confirmed a demand of ₹7.61 crore
  • This was a direct violation of Section 75(7)

The Court observed that Section 75(7) is a statutory safeguard ensuring compliance with principles of natural justice, particularly the rule that no person can be condemned unheard.

7. Court’s Reasoning

The Court held that:

  • A Show Cause Notice must clearly specify the amount of tax, interest and penalty
  • This enables the assessee to effectively respond and defend
  • The adjudicating authority cannot travel beyond the SCN
  • Any order confirming a demand beyond the SCN amount is without jurisdiction

The Court also noted that even though an appellate remedy existed, the writ petition was maintainable because the demand order was ex facie illegal.

8. Final Decision of the Court

The Jammu and Kashmir High Court held that:

  • The final demand order dated 26.08.2021 was unsustainable in law
  • The Show Cause Notice dated 06.02.2021 and the consequential demand order were set aside

Directions Issued

  • The assessing authority was directed to reconsider the matter afresh
  • If the department seeks to demand an amount higher than the SCN, it must:
    • Issue a fresh Show Cause Notice
    • Ensure the notice is within the period of limitation

9. Practical Takeaways for GST Professionals

✔ Final GST demand cannot exceed SCN amount
✔ Section 75(7) is mandatory, not procedural
✔ Authorities cannot improve or enhance demands at adjudication stage
✔ Orders exceeding SCN are void and without jurisdiction
✔ Writ remedy is maintainable for patent statutory violations

Conclusion

This judgment reaffirms that Show Cause Notices define the outer limit of GST adjudication. Any attempt by tax authorities to confirm demands beyond the SCN strikes at the heart of natural justice and is liable to be quashed.

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Section 16(2)(aa) Read Down to Protect Bona-Fide Buyers: ITC Cannot Be Denied Without Giving Opportunity to Prove Genuineness

**Mcleod Russel India Limited

vs.
Union of India & Others**

Gauhati High Court | WP(C) No. 5725 of 2022
Decision Date: 09 December 2025
Coram: Ashutosh Kumar, Chief Justice

1. Background of the Case

The petitioner, Mcleod Russel India Limited, is a public limited company engaged in the production, blending and supply of tea in India and abroad.

The petitioner challenged the constitutional validity and practical operation of Section 16(2)(aa) of the CGST Act, 2017 and the AGST Act, 2017, on the ground that it arbitrarily denies Input Tax Credit (ITC) to bona-fide purchasers due to default of the supplier.

2. Statutory Provision under Challenge

Section 16 – CGST Act, 2017 (Relevant Extract)

Section 16(1)

Provides the substantive right to avail ITC on goods or services used in the course or furtherance of business.

Section 16(2)(aa) (Inserted w.e.f. 01.01.2022)

ITC shall be available only if details of the invoice or debit note have been furnished by the supplier in GSTR-1 and such details are communicated to the recipient under Section 37.

This condition effectively links the buyer’s ITC to the supplier’s compliance.

3. Core Grievance of the Petitioner

The petitioner contended that:

  • Section 16(2)(aa) restricts ITC despite the buyer having paid tax
  • Compliance with Section 37 (GSTR-1 filing) is entirely within the supplier’s control
  • There is no statutory mechanism enabling the buyer to compel supplier compliance
  • ITC is denied merely because invoices do not reflect in GSTR-2A / GSTR-2B
  • This results in double taxation on the buyer:
    • Once by paying GST to the supplier
    • Again by denial of ITC

Such denial defeats the core objective of GST, i.e., tax on value addition and avoidance of cascading effect.

4. Practical Impossibility Highlighted

The Court was apprised that:

  • A supplier may fail to file or correctly file GSTR-1 for various reasons
  • Even if tax is paid in GSTR-3B, ITC is denied due to non-reflection in GSTR-2A/2B
  • The buyer has no legal remedy to correct supplier’s default
  • Denial of ITC under such circumstances is arbitrary and irrational

5. Reliance on CBIC Circulars

The petitioner relied upon:

  • CBIC Circular No. 183/15/2022-GST dated 27.12.2022
  • CBIC Circular No. 193/05/2023-GST dated 17.07.2023

These circulars permitted relaxation of ITC conditions up to 31.12.2021 in cases where invoices were not reflected in GSTR-2A due to supplier default.

It was argued that:

There is no rational basis to presume that supplier-side mistakes ceased after 01.01.2022.

6. Judicial Precedents Relied Upon

The petitioner relied on a strong line of judicial authority protecting bona-fide purchasers:

  1. Suncraft Energy Pvt. Ltd. vs. Assistant Commissioner, State Tax
    (2023) 117 GSTR 78 (Cal)
    Affirmed by Supreme Court – (2024) 121 GSTR 230
  2. Diya Agencies vs. STO
    (2024) 124 GSTR 172 (Kerala HC)
  3. Commissioner Trade & Tax, Delhi vs. Shanti Kiran India Pvt. Ltd.
    (Supreme Court)
    ➤ ITC allowed where buyer acted in good faith and invoices were genuine
  4. On Quest Merchandising India Pvt. Ltd. vs. GNCTD
    (2017 SCC OnLine Del 13037)
    ➤ VAT provision read down to protect bona-fide purchaser

7. Stand of the Revenue

The department argued that:

  • ITC is a concession, not an absolute right
  • Section 16(2) lays down mandatory conditions
  • Section 16(2)(aa) was introduced to:
    • Curb fake ITC
    • Eliminate provisional ITC
    • Ensure supplier compliance
  • The provision is neither arbitrary nor unconstitutional

8. Findings of the Gauhati High Court

The High Court made several important legal observations:

(a) Nature of GST and ITC

  • GST is a tax on the buyer, with the seller acting as a collecting agent
  • ITC exists to prevent cascading of taxes

(b) Excessive Burden on Buyer

  • Section 16(2)(aa) places an onerous and inequitable burden on the buyer
  • Buyer has no control over supplier’s compliance
  • Denial of ITC solely due to GSTR-1 default defeats the scheme of GST

(c) However, Provision Not Declared Unconstitutional

The Court held that:

  • The objective of preventing fraudulent ITC is legitimate
  • Hence, Section 16(2)(aa) is not struck down

9. Section 16(2)(aa) “Read Down” – Key Holding

The Gauhati High Court read down Section 16(2)(aa) and held that:

Before denying ITC to a bona-fide purchaser due to supplier default, the buyer must be given an opportunity to prove his bona fides.

Such bona fides can be verified through:

  • Tax invoices
  • Proof of payment
  • Other supporting documents

10. Temporary Judicial Safeguard

The Court clarified that:

  • This reading down will operate until CBIC provides a practical mechanism
  • ITC availability cannot remain contingent on supplier conduct alone
  • Buyers should not suffer for factors beyond their control

11. Final Decision

  • Section 16(2)(aa) upheld but read down
  • ITC cannot be denied mechanically
  • Opportunity of hearing and verification is mandatory
  • Writ petition disposed of accordingly

12. Key Takeaways for GST Professionals

✔ Section 16(2)(aa) not absolute
✔ Bona-fide buyers deserve procedural protection
✔ ITC denial requires opportunity of proof
✔ Supplier default alone is insufficient
✔ Strong judicial support for substance over form

Conclusion

This judgment is a landmark in ITC jurisprudence, striking a balance between anti-evasion measures and protection of genuine taxpayers. By reading down Section 16(2)(aa), the Gauhati High Court ensured that GST remains a value-added tax and not a punitive levy on honest businesses..

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No Retrospective GST Registration Cancellation Unless Proposed in Show Cause Notice: Delhi High Court

**Globe Coal Company

vs.
Commissioner of DGST, Delhi & Others**

Delhi High Court | W.P. (C) No. 7207 of 2025
Decision Date: 04 December 2025
Coram: Justice Prathiba M. Singh

1. Background of the Case

The petitioner, Globe Coal Company, challenged:

  • Cancellation order dated 17.08.2023, whereby its GST registration was cancelled retrospectively from 21.07.2020, and
  • Appellate order dated 11.03.2025, dismissing the appeal on the ground of limitation.

The cancellation proceedings originated from a Show Cause Notice (SCN) dated 11.11.2021, issued on the allegation that the petitioner was non-functioning / non-existent at its principal place of business.

2. Core Grievance of the Petitioner

The petitioner contended that:

  • The SCN did not propose retrospective cancellation
  • Retrospective cancellation severely prejudices the petitioner by jeopardising Input Tax Credit (ITC) already availed
  • The principal place of business belongs to the petitioner
  • The department could verify the existence of the business through inspection
  • No separate SCN for wrongful availment of ITC was ever issued

On directions of the Court, the Department confirmed that no SCN had been issued regarding ITC.

3. Statutory Provision Involved

Section 29(2) – CGST Act, 2017

Empowers the Proper Officer to cancel GST registration from such date, including any retrospective date, if conditions specified therein are satisfied.

However, the power:

  • Is discretionary
  • Must be exercised with reasons
  • Cannot be applied mechanically or routinely

4. Key Legal Issue Before the Court

Whether GST registration can be cancelled retrospectively when the Show Cause Notice does not propose or put the taxpayer to notice of such retrospective cancellation?

5. Findings of the Delhi High Court

After examining the SCN and the cancellation order, the Court held that:

  • The SCN dated 11.11.2021 did not contemplate retrospective cancellation
  • The cancellation order dated 17.08.2023 cancelled registration retrospectively from 21.07.2020, without notice or reasons
  • Such retrospective cancellation has serious civil consequences, including denial of ITC to the petitioner and its customers

The Court reiterated that:

Retrospective cancellation cannot be imposed unless the taxpayer is specifically put to notice and given an opportunity to object.

6. Reliance on Earlier Delhi High Court Judgments

The Court relied upon and reaffirmed settled law laid down in the following cases:

(a) Riddhi Siddhi Enterprises vs. Commissioner of GST (South Delhi)

W.P.(C) 8061/2024

Key principles laid down:

  • Section 29(2) contains independent grounds for cancellation
  • Retrospective cancellation must be:
    • Reasoned
    • Based on objective criteria
  • Power cannot be exercised robotically
  • Mere non-filing of returns does not justify retrospective cancellation

(b) Ramesh Chander vs. Assistant Commissioner, CGST (Dwarka)

Held that:

  • Neither SCN nor order can be silent on reasons for retrospective cancellation
  • Satisfaction for retrospective cancellation must be objective
  • Authorities must consider the impact on ITC of recipients

(c) Delhi Polymers vs. Commissioner, Trade & Taxes

The Court held:

  • If SCN does not propose retrospective cancellation, the assessee has no opportunity to object
  • Cancellation orders lacking reasons are invalid
  • Retrospective cancellation affecting periods of compliance is impermissible

7. Application of Law to Present Case

Applying the above principles, the Delhi High Court held that:

  • The retrospective cancellation in the petitioner’s case was unsustainable
  • There was an abject failure to assign reasons justifying retroactive effect
  • The appellate authority erred in dismissing the appeal on limitation when the cancellation itself was illegal

8. Directions Issued by the Court

The Court issued the following directions:

  1. GST registration restored
  2. Cancellation order dated 17.08.2023 and appellate order dated 11.03.2025 set aside
  3. GST portal access to be restored within one week
  4. Petitioner to:
    • File all pending returns
    • Pay applicable late fees and penalties, if any
  5. Department is:
    • Free to conduct fresh inspection
    • Entitled to initiate action in accordance with law, if violations are found

9. Important Clarification by the Court

The Court clarified that:

  • If the Department still intends to cancel registration retrospectively,
  • It must issue a fresh Show Cause Notice, specifically proposing such retrospective cancellation,
  • And follow due process of law.

10. Key Takeaways for GST Professionals

✔ Retrospective GST cancellation must be expressly proposed in SCN
✔ Silent SCNs cannot justify retroactive cancellation
✔ Reasons for retrospective effect are mandatory
✔ Mechanical cancellation orders are unsustainable
✔ Courts consistently protect ITC and taxpayer rights

Conclusion

This judgment reinforces a well-settled principle in GST law:
Retrospective cancellation of GST registration is an exceptional power and cannot be exercised without notice, reasons, and application of mind.

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