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One client has Turnover of around 3Cr. He is registered under work contract services under GST. He has failed to file his return on regular basis. He received the notice from GST department for cancellation of the same. Due to non serving of notice, the same has been cancelled now.

Q.1 whether he can reactive his GST No with department or he has to apply for new GST no and consequence of Earlier Cancelled GST No. in current financial year 2017-18

Q.2 He is liable for Tax Audit. Whether CA can do Tax Audit without considering the impact of GST or how many clause he has to qualify for the same. ( including section 43B)


As per Rule 23 of CGST Rules, 2017 Revocation of cancellation of registration is as follows:

1) A registered person, whose registration is cancelled by the proper officer on his own motion, may submit an application for revocation of cancellation of registration, in FORM GST REG-21, to such proper officer, within thirty days from the date of service of the order of cancellation of registration at the Common Portal, either directly or through a Facilitation Centre notified by the Commissioner.

Provided that no application for revocation shall be filed if the registration has been cancelled for the failure of the registered person to furnish returns, unless such returns are furnished and any amount due as tax, in terms of such returns has been paid along with any amount payable towards interest, penalty and late fee payable in respect of the said returns.

2) The auditor will obviously consider the fact that taxpayer did not file the return within stipulated time and failed to make payment of tax as well. And qualification for non compliance with the GST law will be in the audit report.  

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