HIGH COURT OF JUDICATURE AT ALLAHABAD LUCKNOW WRIT TAX No. - 931 of 2025 Court No. - 6 HON'BLE PANKAJ BHATIA, J. 1. Supplementary affidavit filed today in Court is taken on record. 2. Heard learned counsel for the petitioner and Shri K.D. Nag, learned counsel for the respondent. 3. Present petition has been filed challenging the order dated 25.05.2024 whereby the registration of the petitioner was cancelled as well as the order dated 28.08.2025 whereby the appeal was dismissed as being beyond limitation. 4. Contention of learned counsel for the petitioner is that the petitioner was served with a show cause notice proposing to cancel the registration, however, the petitioner could not reply and an order came to be passed cancelling the registration on 25.05.2024. The said order is on record as Annexure - 2. It is argued that the same is passed without any reason whatsoever. 5. Learned counsel for the respondent states that no reply was given by the petitioner to the show cause notice and it appears that the registration was obtained on false ground, as such, some time may be granted for filing counter affidavit. 6. The said request, being most unreasonable, is rejected for the reason that the counter affidavit cannot supplement the reasoning as contained in Versus Counsel for Petitioner(s) : Satish Kumar Pandey Counsel for Respondent(s) : A.S.G.I., Kuldeepak Nag (K.D.Nag) M/S Sanjay Construction Company Sultanpur Thru. Proprietor Kalpana Verma .....Petitioner(s) U.O.I. Thru. Secy. Ministry Of Finance North Block New Delhi And 2 Others .....Respondent(s) the order. The order of cancellation is a non-speaking order and does not record any reason whatsoever except the following: " the effective date of cancellation of your registration is 11/10/2023" 7. It is well settled that reasoning is heart and soul of any adjudicatory order and the same is absent in the order impugned. 8. A similar issue was considered by this Court in the case of M/s Chandra Sain, Sarda Nagar, Lucknow Thru. Its Proprietor v. U.O.I & Ors. (Writ Tax No.147 of 2022) decided on 22.09.2022. 9. Following the said judgment, both the impugned orders dated 25.05.2024 & 28.08.2025 are quashed. 10. Matter is remanded back to the assessing authority to pass fresh order after giving an opportunity of hearing to the petitioner. 11. Present petition stands allowed in above terms. September 22, 2025 nishant WTAX No. 931 of 2025 2 (Pankaj Bhatia,J.) Digitally signed by :- NISHANT MOHAN High Court of Judicature at Allahabad, Lucknow Bench