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GST · Notices & appealsGST registration suspension and revocation: REG-31, REG-17 and REG-21
A suspended or cancelled GSTIN stops your business – buyers cannot take ITC, e-way bills cannot be generated and refunds stop. Here is why it happens, how to respond to REG-31 and REG-17, and how to get the registration restored through REG-21.
GST registration can be suspended (temporary) under Section 29(2) and Rule 21A, and cancelled by the officer. The forms are REG-31 (intimation of suspension / discrepancy), REG-17 (show cause for cancellation), REG-18 (reply), REG-19 (cancellation order), and REG-21 (revocation application).
Common triggers
| Trigger | Form |
|---|---|
| Not filing GSTR-3B for the prescribed period (e.g. two consecutive tax periods for monthly filers, as per rules) | REG-31 / REG-17 |
| GSTR-1 outward supplies far exceed GSTR-3B | REG-31 |
| ITC in 3B far exceeds 2B | REG-31 |
| Business not found at the declared address | REG-17 |
| Registration obtained by fraud or wilful misstatement | REG-17 |
| Not starting business within 6 months of voluntary registration | REG-17 |
Responding to REG-31 / REG-17
- Read the reason and reply window (REG-31 typically 30 days; REG-17 typically 7 working days in REG-18).
- File all pending returns with late fee and interest.
- Explain mismatches with reconciliation.
- For address issues: upload proof of premises, photographs, rent agreement, electricity bill; request verification.
- Reply in the portal; keep the acknowledgement.
If satisfied, the officer drops proceedings (REG-20) and the suspension is lifted.
Revocation after cancellation
| Point | Rule |
|---|---|
| Form | REG-21 |
| Time | Within 90 days of cancellation order; extension up to 180 days by the authorities on sufficient cause (Rule 23 as amended) |
| Condition | File all returns due up to the cancellation date, with tax, interest and late fee |
| Order | REG-22 (revoked) or REG-05 (rejected after REG-23 notice) |
| Appeal | Section 107, within 3 months of rejection |
Courts have also allowed revocation beyond these periods in deserving cases, using writ jurisdiction, but that is expensive and uncertain.
Worked example
Example: Metro Supply Co. (Pitampura) did not file GSTR-3B for June and July 2026 due to cash constraints. On 25 August 2026, its registration was suspended via REG-31, and on 5 September a REG-17 was issued.
- Metro Supply Co. files June and July GSTR-3B with tax, interest and late fee (₹50/day each, within caps) by 10 September.
- Replies in REG-18 on 11 September stating returns filed and seeking withdrawal.
- Officer drops proceedings; suspension revoked.
Had Metro Supply Co. ignored REG-17, a cancellation order (REG-19) would follow; Metro Supply Co. would then have 90 days to file REG-21 after filing all returns.
Effect of suspension and cancellation
- No taxable supplies; buyers cannot claim ITC on invoices during suspension.
- E-way bills cannot be generated.
- Refunds blocked.
- On cancellation, pay tax on stock and capital goods (GSTR-10 final return within 3 months).
Common mistakes
- Ignoring portal notices (the email may go to an old address).
- Filing REG-21 without filing returns.
- Missing the 90-day window.
- Not filing GSTR-10 after cancellation.
Key takeaway
Most suspensions are cured by filing pending returns and replying promptly. If cancelled, file returns and REG-21 within 90 days. Keep the registered email and mobile updated. Our GST team handles suspension replies and revocation applications.
Official references
Provisions discussed (summaries in our Law Library):
- CGST Act, 2017 – Section 29: Cancellation or suspension
- CGST Act, 2017 – Section 30: Revocation of cancellation
Official sources to verify the current text, notifications and circulars:
Frequently asked questions
Why is a GST registration suspended?
Common reasons are non-filing of returns, significant differences between GSTR-1/3B and GSTR-2B, non-existence at the declared address, or failure in Aadhaar authentication. Suspension can be system-generated under Rule 21A.
What is the time limit to apply for revocation?
An application in REG-21 must be filed within 90 days of the cancellation order, extendable by up to 180 days on sufficient cause, as per the amended Rule 23.
Can I file returns while my registration is suspended?
During suspension you cannot make taxable supplies, but you must file pending returns to get the suspension lifted.
What if revocation is rejected?
You can appeal under Section 107 within three months of the rejection order.
Can a cancelled taxpayer apply for fresh registration instead of revocation?
Fresh registration on the same PAN in the same State may be refused if the earlier registration was cancelled for default and dues are pending. Revocation is the normal route.
Do I need to pay tax on stock on cancellation?
Yes. On cancellation, ITC on stock and capital goods (with adjustments) must be reversed or paid through GSTR-10.
Is there a fee for revocation?
No separate fee, but all pending returns with late fees and interest must be filed first.
This article is general information on the law as on 10 November 2026, written for educational purposes. It is not professional advice for your case. Section numbers under the Income-tax Act, 2025 should be confirmed with the official section mapping on the Income Tax Department website before use in filings.
Have a tax, GST or business question?
Call, WhatsApp or email CA Dilbagh Singh and team, from Delhi, anywhere in India or abroad.