System‑Generated Cancellation Notice Without Officer’s Name Invalid, Orders Set Aside: Allahabad High Court

Following its own Division Bench rulings, the Allahabad High Court set aside a GST registration cancellation and the appellate order because the show cause notice was system‑generated and named no issuing officer.

The Allahabad High Court has set aside the cancellation of a contractor’s GST registration and the appellate order upholding it, because the show cause notice (SCN) was a system‑generated notice of the “jurisdictional officer” that did not identify the officer or office issuing it [Iqwal Khan Civil Construction Company v. State of U.P. & Ors., 2026-juristway.com-3366-HC(Allahabad)-GST].

Justice Vikas Budhwar decided the petition on the record with the consent of both sides. An SCN dated 15 Oct 2025 in Form GST REG‑31 proposed cancellation. It carried the line “Contact Jurisdiction Office for further process” and was digitally signed in the name of the Goods and Services Tax Network. An order dated 1 Dec 2025 in Form GST REG‑19 cancelled the registration for non‑filing of returns, recording that no reply had been filed. The appeal was rejected on 14 Aug 2026.

The petitioner argued that the power to issue the notice lay with the assigned officer, who had to apply his mind, and not with the system. The State replied that the petitioner could have raised the objection in a reply to the notice, and that the appeal had also been rejected for delay.

The Court held that the issue was no longer res integra. In Bhaiyalal Contractors v. State of U.P. (Special Appeal Defective No. 883 of 2025), a Division Bench followed M Y Ent Bhatta v. State of U.P. (2025:AHC:78209‑DB), which held that because the power lies with officers and not with the system, a system‑generated notice bearing neither the name nor the office of the issuing authority is outside the Act and the Rules.

The Division Bench in Bhaiyalal Contractors also held that dismissal of the appeal as time‑barred did not stop the writ court from examining the validity of the notice itself. The same view was applied in Sagar Traders v. State of U.P. (Writ Tax No. 3277 of 2026).

Concluding that the notice ought to have been issued in accordance with law, the Court set aside the cancellation order passed under Section 29 of the State Goods and Services Tax Act and the appellate order. The authorities remain free to issue a fresh SCN in accordance with law.

2026-juristway.com-3366-HC(Allahabad)-GST