Patna High Court Dismisses Writ Petition Over GST Registration Cancellation, Highlights Importance of Timely Action

Reiterating the principle that “the law favours the diligent and not the indolent,” the Court held that the petitioner’s failure to act within the prescribed timelines precluded any claim for relief.

The Patna High Court has dismissed a writ petition filed by Rani Enterprises against the cancellation of its GST registration. The case, Rani Enterprises v. Union of India (CWJ No.15878/2024), underscores the critical importance of adhering to statutory timelines when seeking legal remedies.

Chief Justice K. Vinod Chandran and Justice Partha Sarthy, presiding over the matter, emphasized the maxim, “The law favours the diligent and not the indolent,” while rejecting the petition.

Background of the Case

Rani Enterprises faced cancellation of its GST registration but failed to utilize the statutory appellate remedies provided under the Bihar Goods and Services Tax Act, 2017 (BGST Act). The cancellation order, issued on December 30, 2022, could have been contested by filing an appeal under Section 107 of the BGST Act. However, the petitioner missed the three-month appeal window, as well as the one-month grace period for condonation of delay, which expired on April 29, 2023.

Additionally, Section 30 of the GST Act allows taxpayers to apply for revocation of cancellation within 30 days of the cancellation order. The petitioner also failed to submit a revocation application within the stipulated period.

Missed Amnesty Scheme Opportunity

To further assist taxpayers, the government introduced an Amnesty Scheme via GST Circular No. 3 of 2023, which enabled taxpayers with cancelled registrations to reinstate their status by clearing outstanding dues between March 31, 2023, and August 31, 2023. Despite this extended relief measure, Rani Enterprises did not take any steps to restore its registration.

Court’s Observations

The Court noted that the petitioner’s GST registration had already been cancelled during the contested period, leaving no mechanism to monitor the petitioner’s business activities. This lack of oversight raised concerns about the feasibility and authenticity of any transactions conducted while the registration was inactive.

Reiterating the principle that “the law favours the diligent and not the indolent,” the Court held that the petitioner’s failure to act within the prescribed timelines precluded any claim for relief. Consequently, the writ petition was dismissed.

Key Takeaways

This judgment serves as a critical reminder for businesses to adhere to statutory deadlines and leverage available remedies and schemes in a timely manner. Procrastination in addressing legal issues can result in irreversible consequences, as highlighted by the Court’s decision in this case.

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