The petitioner challenged retrospective cancellation of GST registration on the sole ground of non-payment of tax for a period exceeding three months. The factual background showed that the show cause notice cited only delay in payment of tax, interest or penalty as the reason for cancellation, without referring to any statutory ground under Section 29 of the CGST Act. The notice also did not specify any date or time for personal hearing.

The Court held that failure to pay tax beyond three months is not a ground for cancellation under Section 29 of the CGST Act. Cancellation of registration must strictly conform to statutory conditions and cannot be sustained on grounds not recognised by law. The impugned cancellation order was set aside.