Telangana High Court allows fresh revocation plea despite earlier rejection for non‑reply to SCN
Overview
In Anjaneya Kirana Merchants Vs Deputy State Tax Officer (Telangana High Court) (Writ Petition No: 10424 of 2026, decided on 08/04/2026), the Telangana High Court considered whether an assessee whose application for revocation of cancellation of GST registration had been rejected for non‑response to a show cause notice could be given another opportunity, even though the statutory time for appeal had already lapsed.
The Court did not itself restore the GST registration. Instead, it permitted the assessee to file a fresh application for revocation of cancellation manually within a specified timeframe and directed the competent authority to examine that application strictly in accordance with law, without being influenced by the earlier rejection.
Factual background
Cancellation of GST registration
- The assessee’s GST registration was cancelled by an order dated 20.11.2025, issued in FORM GST REG‑19.
- Following this, the assessee invoked the statutory mechanism and filed an application before the competent authority seeking revocation of the cancellation of registration.
Show cause notice and rejection of revocation application
- On 04.12.2025, the competent authority issued a show cause notice in relation to the revocation application.
- The assessee did not submit any reply to the said show cause notice.
- Due to non‑filing of reply, the authority passed an order dated 17.12.2025, rejecting the assessee’s application for revocation of cancellation of registration.
- By the time the order rejecting the revocation application was passed, the prescribed limitation period for filing an appeal against the cancellation order had already run out.
Thus, as on 17.12.2025, the assessee had:
- A subsisting cancellation of GST registration;
- A rejected revocation application owing to non‑reply to the show cause notice; and
- No available appellate remedy on account of expiry of limitation.
Submissions on behalf of the assessee
Reason for non‑response to the show cause notice
Learned counsel for the assessee explained that:
- The assessee had entrusted the responsibility of filing monthly GST returns and attending to GST compliance to its accountant.
- The assessee asserted that it was not aware of the issuance of the show cause notice dated 04.12.2025.
- The non‑filing of reply was, therefore, projected as an inadvertent lapse and not a deliberate act of non‑cooperation.
Relief requested before the High Court
Relying on the above explanation, the assessee sought indulgence of the Court and requested:
- Either: permission to now submit a reply to the original show cause notice so that the earlier revocation application could be reconsidered on merits;
- Or: a direction permitting the assessee to file a fresh application for revocation of cancellation of GST registration to be considered afresh by the competent authority.
In essence, the assessee asked the Court to open a fresh window for revocation proceedings despite the closure of the usual statutory avenues.