Answer

1. F

   Facts

   Sec 29(2) allows cancellation from a back date. Courts have said this needs reasons, not a mechanical order. A back-dated cancellation can put your buyers' ITC at risk for that period.

2. P

   Provisions and law

   • Sec 29(2), CGST Act 2017The officer can cancel registration, even from a back date, for contravention, non-filing of returns or registration obtained by fraud, after giving a hearing
   • Sec 16(2)(c), CGST Act 2017Buyer gets ITC only if the tax charged has been paid to the government
3. A

   Analysis

   If you filed returns and paid tax for those two years, a retrospective date harms your genuine buyers, which is a strong ground in appeal. Ask why that date was chosen. If the order gives no reasons for the back date, that itself is a point to raise. Keep proof of returns filed and tax paid for each month.

4. C

   Conclusion

   1. 1Read the order for the effective date and reasons.
   2. 2Collect proof of returns filed and tax paid.
   3. 3File an appeal or revocation as applicable, challenging the back date.
   4. 4Inform key buyers so they are not caught off guard.

Ignoring a back-dated cancellation can lead to buyers' ITC being questioned and claims against you.

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.