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Appellant has not been complied with the first proviso of Rule 23 of CGST Rules, 2017. Hence, in view of this, the cancellation of registration of appellant may not be considered for revocation.

Revocation of Cancelled registration- Rule 23 of CGST Rules- In the instant case, the Proper Officer has cancelled the GSTIN of petitioner due to non filing of returns for a continuous period of six months. The application for revocation of cancellation of registration has been also rejected due to non submission of reply to the show cause notice. the appellant did not discharge their total interest liability rather he stated that since he had not paid any tax liability through cash hence no any interest liability arised as per press note released on 22nd December 2018. However, in this context I find that in terms of proviso of Section 50 of CGST Act, 2017 amended vide Notification No.63/2020- C.T dated 25.08.2020 interest liability on net tax has been considered on prospective date i.e. with effect from 1st Sept 2020. Held that- the appellant has not been complied with the first proviso of Rule 23 of CGST Rules, 2017. Hence, in view of this I am the opinion that the cancellation of registration of appellant may not be considered for revocation. Accordingly, I reject the appeal of the appellant.
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