About GST Revocation
Revocation of suo motu cancellation in REG-21 within 90 days extendable to 180 days. Forms handled: REG-21, REG-22, REG-23. Legal basis: Section 30 CGST Act and Rule 23.
Plain-English glossary for this service
DRC-03 voluntary payment is used during revocation preparation where the cause of cancellation involves under-declared liability discovered during arrears reconciliation. Filing DRC-03 alongside REG-21 strengthens the bona fides of the revocation application and may shorten officer-side scrutiny.
Continuity of business is the factual element a revocation applicant must demonstrate — that the underlying business has not been discontinued and there is a genuine intent to resume compliant operations. Recent invoices, employee records, premises evidence and bank statements are commonly relied upon.
REG-24 is the taxpayer's reply to a REG-23 show-cause, carrying clarifications, documentary proof of return-filing, payment challans, and submissions on reasonable cause. It must be filed within seven working days of REG-23 to avoid REG-05 rejection.
Aggregate dues refers to the consolidated amount of tax, interest under Section 50 and late fee under Section 47 that must be discharged through the Electronic Cash Ledger before REG-21 can be submitted. The portal validates the ECL balance against the dues at submission stage.
Suspension flag is the Rule 21A operational marker on a GSTIN that bars invoice issuance and ITC pass-through during pendency of cancellation proceedings. A successful REG-22 revocation lifts both the cancellation and the underlying suspension flag from the common portal.
The Section 30 window is the 90-day period commencing from the date of service of the cancellation order under Section 29(2) within which the revocation application in REG-21 must ordinarily be filed. The Commissioner can extend this by a further 180 days, giving an outer 270-day limit.
Portal access restoration is the practical step of regaining login credentials on the common portal when the original signatory or business owner has lost access. It frequently involves PAN-Aadhaar based credential reset and is a precondition to filing the defaulted returns that revocation requires.
Form ITC-01 is filed within 30 days of grant of fresh registration under Section 18(1) to claim input tax credit on inputs held in stock, inputs contained in semi-finished or finished goods, and capital goods on the day immediately preceding the date of grant. Useful where Section 30 revocation has lapsed and fresh REG-01 is the only option — recovers part of the stranded ITC.
REG-23 is the show-cause notice issued by the proper officer proposing to reject a REG-21 revocation application — typically on grounds of unfiled returns, unpaid dues, or insufficient explanation for delay beyond the 90-day window. Reply lies in REG-24 within seven working days.
REG-22 is the order passed by the proper officer revoking a suo motu cancellation, restoring the GSTIN with effect from the date specified in the order. The order is communicated electronically and is the formal end-point of a successful revocation proceeding.
REG-22 is the order passed by the proper officer either revoking the cancellation or rejecting the REG-21 application. To be passed within 30 working days of REG-21 filing per Rule 23. A favourable REG-22 restores the GSTIN with continuity from the cancellation date — no break in the ITC chain for downstream buyers.
Notification No. 07/2023 – Central Tax dated 31 March 2023 capped the late fee for GSTR-3B and GSTR-4 returns filed during the revocation amnesty window provided by Notification 03/2023-CT. The cap brought down the late-fee burden for older-period returns and made the amnesty financially viable for small taxpayers.
Operative provisions cited on this page
Every claim on this page can be traced back to a section or rule below.
Section 30 of the Central Goods and Services Tax Act 2017 is the substantive provision empowering a registered person whose registration has been cancelled suo motu by the proper officer under Section 29(2) to seek restoration. Sub-section (1) of Section 30 provides that the application shall be filed in the prescribed manner within ninety days from the date of service of the cancellation order. The first proviso, as substituted by the Finance Act 2023, empowers the Commissioner or an officer authorised by him to extend the said period of ninety days by such further period not exceeding one hundred and eighty days. It is to be noted that revocation is available only against suo motu cancellation and not against voluntary cancellation under Section 29(1).
View sourceSection 29 is the gateway provision because revocation under Section 30 lies only against an order passed under Section 29(2). Sub-section (2) of Section 29 lists the suo motu grounds — contravention of prescribed provisions, non-filing of returns for the prescribed period, voluntary registration holder not commencing business within six months, registration obtained by fraud or wilful misstatement, or violation of Section 171 anti-profiteering. It is to be noted that the proper officer must afford an opportunity of being heard under the proviso before passing the cancellation order, failing which the order is itself amenable to challenge before revocation is even invoked.
View sourceSub-rule (1) of Rule 23 of the CGST Rules prescribes Form GST REG-21 as the application for revocation, filed electronically on the common portal. The application must accompany payment of all dues, filing of all pending returns and payment of late fee and interest. Sub-rule (2) requires the proper officer, on being satisfied, to revoke the cancellation in Form REG-22 within thirty days. Sub-rule (3) prescribes Form REG-23 as the show-cause where the officer proposes to reject the revocation application, calling for reply in Form REG-24 within seven working days.
View sourceRule 22 prescribes the procedure preceding suo motu cancellation under Section 29(2). Sub-rule (1) requires issuance of show-cause in Form REG-17, reply in Form REG-18 within seven working days, and order of cancellation in Form REG-19 within thirty days of reply. Sub-rule (4) is critical for revocation practice — if the taxpayer files all pending returns and pays the dues during the pendency of cancellation proceedings, the officer may drop the proceedings by passing an order in Form REG-20, obviating the need for revocation under Section 30 altogether.
View sourceSection 39 of the CGST Act mandates monthly or quarterly return filing in Form GSTR-3B by every registered person. The first proviso to sub-rule (1) of Rule 23 bars the proper officer from accepting a REG-21 revocation application unless every return due till the date of cancellation order is furnished and the tax payable along with interest under Section 50 and late fee under Section 47 is discharged. Non-furnishing of returns under Section 39 for the prescribed continuous period itself constitutes the trigger for suo motu cancellation under Section 29(2)(c).
View sourceSection 47 prescribes the late fee payable for delayed furnishing of returns under Section 39 read with Section 37. Sub-section (1) of Section 47 imposes a late fee of two hundred rupees per day (one hundred CGST and one hundred SGST) subject to a maximum of five thousand rupees per return. It is to be noted that the late fee is payable for every pending return that the taxpayer files as a precondition for the revocation application, and Notification 07/2023-Central Tax provides a specific cap for revocation cases where returns relate to financial years up to 2021-22.
View sourceSection 50 levies interest at eighteen per cent per annum on tax paid after the due date prescribed under Section 39. Sub-section (1) of Section 50 applies to all delayed cash payments, while the proviso, inserted with retrospective effect from 1 July 2017, limits the interest computation to the net cash liability (excluding ITC-discharged portion). Interest is a non-negotiable component of the dues that must be paid before REG-21 can be entertained, and unlike late fee it is not capped by any notification.
View sourceThe Finance Act 2023 substituted the proviso to sub-section (1) of Section 30 with effect from 1 October 2023. The earlier two-tier extension — sixty days by the Additional or Joint Commissioner and a further sixty days by the Commissioner — was replaced with a single outer extension of one hundred and eighty days exercisable by the Commissioner or an officer authorised by him. The total outer window from the date of cancellation order therefore stands at two hundred and seventy days, beyond which Section 30 itself ceases to be available and the taxpayer must apply for fresh registration in Form REG-01.
View sourceForms used in this engagement
Electronic application by a taxpayer for revocation of suo motu cancellation under Section 29(2); requires furnishing of all pending returns and payment of dues before submission is accepted by the common portal
Order passed by the proper officer revoking the suo motu cancellation and restoring the GSTIN; communicated electronically through the common portal
Notice issued by the proper officer where prima facie grounds exist to reject the REG-21 revocation application — typically incomplete returns, unpaid arrears, or insufficient reasoning for delay
Taxpayer's reply to REG-23 carrying clarifications, documentary proof of return-filing, payment challans, and submissions on reasonable cause for delay
Order of the proper officer rejecting the REG-21 revocation application after considering REG-24 reply or where no reply is received within the prescribed time
Cancellation order under Section 29(2) which is the order against which revocation under Section 30 is sought; the date of its communication starts the 90-day Section 30 clock
Show-cause notice preceding suo motu cancellation — addressing this at the REG-18 stage pre-empts the need for later revocation under Section 30
Taxpayer's reply to the REG-17 show-cause; filing of all defaulted returns during this window can lead to REG-20 dropping of proceedings
Order dropping cancellation proceedings where the REG-18 reply is satisfactory — typically because all pending returns have been filed with dues paid
Summary monthly return capturing output tax, ITC availed, and net tax paid; every defaulted GSTR-3B for the period up to cancellation must be filed before REG-21 can be entertained
Monthly or quarterly statement of outward supplies; defaulted GSTR-1 filings up to date of cancellation are a precondition for REG-21
Annual return for composition taxpayers under Section 10; revocation by a composition taxpayer requires every defaulted GSTR-4 to be filed first
Compliance deadlines that matter
Miss any of these and the next consequence kicks in automatically.
Standard 90-day route vs Extended 180-day Commissioner route
Three named tax practitioners — not a faceless outsourcer
B.Com, CA Inter, GST Practitioner. 15+ years and 500+ Chennai engagements. Leads the notice-reply and CMA project-report practice.
B.Com. 15+ years in statutory and ROC compliance, partnership-firm matters, and audit-support engagements.
B.Com, M.Com. 5+ years on monthly GST returns, GSTR-2B reconciliation, and ASMT-10 first-touch responses.