CWP-8881-2026 IN THE HIGH COURT OF PUNJAB AND HARYANA AT M/s North Steel India Union of India and others CORAM : HON’BLE MR. JUSTICE HON’BLE MS. JUSTICE LAPITA BANERJI Present : Mr. Ish Puneet Singh, Advocate, for the petitioner. Mr. Rishabh Kapoor, Advocate, for respondents Mr. Saurabh Kapoor, Additional A.G., Punjab Ms. Muskaan Gupta, Advocate, for respondents No.5 to 8. DEEPAK SIBAL Learned counsel for the petitioner restricts his claim to the challenge to the show cause notice petitioner with regard to 2. The impugned show cause notice dated 05.01.2026 reads as under:- Reference No.: ZA030126007296Z To Registration Number (GSTIN/UIN): 03CAEPG7493M1ZD GOLDY GODOWN NO INDIA, NEAR CANAL, AMLOH ROAD, OPP DOABA MILL, DASHMESH COLONY, Mandi Govindgarh, Fatehgarh Sahib, Punjab, 147301 2026 (O&M) Sr. No.145 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CWP-8881 Date of Decision : M/s North Steel India Versus Union of India and others HON’BLE MR. JUSTICE DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Ish Puneet Singh, Advocate, for the petitioner. Mr. Rishabh Kapoor, Advocate, for respondents No.1 to 4. Mr. Saurabh Kapoor, Additional A.G., Punjab Ms. Muskaan Gupta, Advocate, for respondents No.5 to 8. *** DEEPAK SIBAL, J. (Oral) Learned counsel for the petitioner restricts his claim to the challenge to the show cause notice dated 05.01.2026 served upon the petitioner with regard to cancellation of its GST registration. The impugned show cause notice dated 05.01.2026 reads as “FORM GST REG [See Rule 22(1)] Reference No.: ZA030126007296Z To Registration Number (GSTIN/UIN): 03CAEPG7493M1ZD GOLDY GODOWN NO-171, GROUND FLOOR, NORTH STEEL INDIA, NEAR CANAL, AMLOH ROAD, OPP DOABA MILL, DASHMESH COLONY, Mandi Govindgarh, Fatehgarh Sahib, Punjab, 147301 Show Cause Notice for Can p. 1 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 8881-2026 (O&M) Date of Decision : 30.04.2026 …Petitioner …Respondents DEEPAK SIBAL HON’BLE MS. JUSTICE LAPITA BANERJI Mr. Saurabh Kapoor, Additional A.G., Punjab and Learned counsel for the petitioner restricts his claim to the dated 05.01.2026 served upon the cancellation of its GST registration. The impugned show cause notice dated 05.01.2026 reads as FORM GST REG-17 [See Rule 22(1)] Reference No.: ZA030126007296Z Date:05/01/2026 Registration Number (GSTIN/UIN): 03CAEPG7493M1ZD 171, GROUND FLOOR, NORTH STEEL INDIA, NEAR CANAL, AMLOH ROAD, OPP DOABA MILL, DASHMESH COLONY, Mandi Govindgarh, Fatehgarh Sahib, Show Cause Notice for Cancellation of Registration VANDANA 2026.05.06 09:36 I attest to the accuracy and integrity of this document CWP-8881-2026 Whereas on the basis of information which has come to my notice, it appears that your registration is liable to be cancelled for the following reasons: 1. Section 29(2)(e) wilful misstateme 2. Rule 21 (a) declared place of business/place of business not found 3. Rule 21(b) goods or services or both in violation of the provis Act, or the rules made thereunder 4. Rule 21(e) of section 16 of the Act or the rules made thereunder 5. Rule 21(g) 6. Others Remarks: The firm was found authorities and they have requested to initiate cancellation proceedings of the GSTN. It appears that the registration was obtained by means of fraud, wilful misstatement or suppression of facts. Further, on scruti GST portal, it was found that the major suppliers of the firm has been cancelled suo passing fake ITC. It appears that the your firm has been operating on papers only and had also been e availing & passing of fake ITC without actual movement of goods in contravention to the CGST Act, 2017, hence, your GST no. is liable for cancellation with retrospective effect i.e. from the date of registration. It is, therefore, requested to su attend the personal hearing with relevant records, if any, which you want to produce in your defence. Otherwise, your GST No. will be cancelled retrospectively & further proceedings will be initiated 2017 to recover the government dues. 2026 (O&M) Whereas on the basis of information which has come to my notice, it appears that your registration is liable to be cancelled for the following reasons: 1. Section 29(2)(e)-registration obtained by means of fraud, wilful misstatement or suppression of facts 2. Rule 21 (a) - Person does not conduct any business from declared place of business/place of business not found 3. Rule 21(b)- person issues invoice or bill without supply of goods or services or both in violation of the provis Act, or the rules made thereunder 4. Rule 21(e)-person avails ITC in violation of the provisions of section 16 of the Act or the rules made thereunder 5. Rule 21(g)-person violates the provision of rule 86B 6. Others Remarks: The firm was found non-existent during PV conducted by SGST authorities and they have requested to initiate cancellation proceedings of the GSTN. It appears that the registration was obtained by means of fraud, wilful misstatement or suppression of facts. Further, on scrutiny of the records available on the GST portal, it was found that the major suppliers of the firm has been cancelled suo-moto from date of registration for passing fake ITC. It appears that the your firm has been operating on papers only and had also been e availing & passing of fake ITC without actual movement of goods in contravention to the CGST Act, 2017, hence, your GST no. is liable for cancellation with retrospective effect i.e. from the date of registration. It is, therefore, requested to submit your reply in r/o above charges within due date and attend the personal hearing with relevant records, if any, which you want to produce in your defence. Otherwise, your GST No. will be cancelled retrospectively & further proceedings will be initiated against you under the CGST Act, 2017 to recover the government dues. p. 2 Whereas on the basis of information which has come to my notice, it appears that your registration is liable to be cancelled for the following reasons: registration obtained by means of fraud, nt or suppression of facts Person does not conduct any business from declared place of business/place of business not found person issues invoice or bill without supply of goods or services or both in violation of the provisions of the Act, or the rules made thereunder person avails ITC in violation of the provisions of section 16 of the Act or the rules made thereunder person violates the provision of rule 86B existent during PV conducted by SGST authorities and they have requested to initiate cancellation proceedings of the GSTN. It appears that the registration was obtained by means of fraud, wilful misstatement or suppression ny of the records available on the GST portal, it was found that the major suppliers of the firm moto from date of registration for passing fake ITC. It appears that the your firm has been operating on papers only and had also been engaged in availing & passing of fake ITC without actual movement of goods in contravention to the CGST Act, 2017, hence, your GST no. is liable for cancellation with retrospective effect i.e. from the date of registration. It is, therefore, requested to bmit your reply in r/o above charges within due date and attend the personal hearing with relevant records, if any, which you want to produce in your defence. Otherwise, your GST No. will be cancelled retrospectively & further against you under the CGST Act, 2017 to recover the government dues. VANDANA 2026.05.06 09:36 I attest to the accuracy and integrity of this document CWP-8881-2026 You are hereby directed to furnish a reply to the notice within seven working days from the date of service of this notice. You are hereby directed to appear before the undersigned autho If you fail to furnish a reply within the stipulated date or fail to appear for personal hearing on the appointed date and time, the case will be decided ex parte on the basis of available records and on merits. Please note tha from 23/08/2024. Kindly refer the supportive document attached for case specific details. Place: CBIC Date: 05.01.2026 3. A perusal of the afore quoted show cause notice reveals that the same is based on physical verification conducted by the State authorities as per which the petitioner of the records available on the GST por registration of retrospective effect as also that it h actual movement of goods. 4. In support of the afore basis, been supplied to the petitioner. GST registration Details as to how the petitioner is availing/passing on fake I without actual movement of good in the impugned 2026 (O&M) You are hereby directed to furnish a reply to the notice within seven working days from the date of service of this notice. You are hereby directed to appear before the undersigned authority on 14/01/2026 at 10:30. If you fail to furnish a reply within the stipulated date or fail to appear for personal hearing on the appointed date and time, the case will be decided ex parte on the basis of available records and on merits. Please note that your registration stands suspended with effect from 23/08/2024. Kindly refer the supportive document attached for case specific details. Place: CBIC Date: 05.01.2026 A perusal of the afore quoted show cause notice reveals that the same is based on physical verification conducted by the State authorities as per which the petitioner-firm was not found to exist. records available on the GST portal registration of the petitioner’s major suppliers having been cancelled retrospective effect and that the petitioner had been operating on paper only as also that it had been availing/passing on fake I actual movement of goods. In support of the afore basis, no physical verification report been supplied to the petitioner. No details with regard to cancellation of GST registration of any of its major suppliers as to how the petitioner is availing/passing on fake I without actual movement of goods are also missing. impugned show cause notice that for specific details p. 3 You are hereby directed to furnish a reply to the notice within seven working days from the date of service of this notice. You are hereby directed to appear before the undersigned rity on 14/01/2026 at 10:30. If you fail to furnish a reply within the stipulated date or fail to appear for personal hearing on the appointed date and time, the case will be decided ex parte on the basis of available t your registration stands suspended with effect Kindly refer the supportive document attached for case specific Ashish Kumar Singh Superintendent Range-IV” A perusal of the afore quoted show cause notice reveals that the same is based on physical verification conducted by the State authorities firm was not found to exist. Further, on scrutiny it had been found that GST the petitioner’s major suppliers having been cancelled with he petitioner had been operating on paper only sing on fake Input Tax Credit without physical verification report has o details with regard to cancellation of major suppliers has also been furnished. as to how the petitioner is availing/passing on fake Input Tax Credit missing. Though it is mentioned for specific details supportive VANDANA 2026.05.06 09:36 I attest to the accuracy and integrity of this document CWP-8881-2026 documents are appended along with the impugned show cause notice served upon the petitioner. 5. In the light of the above, the impugned show cause notice dated 05.01.2026 not serve the purpose behind it 22 of the Central aside the show cause notice dated 05.01.2026 (Annexure P to the respondents to proceed with law. 6. The petition is allowed in the above terms. April 30, 2026 vandana Whether speaking/reasoned : Whether reportable 2026 (O&M) are attached but admittedly, no such supportive along with the impugned show cause notice served upon the In the light of the above, the impugned show cause notice dated 05.01.2026 is violative of the principles of natural justice and serve the purpose behind its issuance. It is also against the spirit of Rule entral Goods and Services Tax Rules 2017 show cause notice dated 05.01.2026 (Annexure P to the respondents to proceed afresh against the petitioner in accordance The petition is allowed in the above terms. (DEEPAK SIBAL JUDGE (LAPITA BANERJI) JUDGE , 2026 ther speaking/reasoned : Yes/No Whether reportable : Yes/No p. 4 such supportive documents were along with the impugned show cause notice served upon the In the light of the above, the impugned show cause notice is violative of the principles of natural justice and does . It is also against the spirit of Rule Rules 2017. Therefore, we set show cause notice dated 05.01.2026 (Annexure P-2) with liberty against the petitioner in accordance The petition is allowed in the above terms. DEEPAK SIBAL) JUDGE (LAPITA BANERJI) JUDGE VANDANA 2026.05.06 09:36 I attest to the accuracy and integrity of this document