Section 12AB registration cannot be refused on an unverified assumption of missing documents where substantial compliance is shown.

An application for registration under section 12AB cannot be rejected on an unverified assumption of incomplete disclosure where the record indicates that the required particulars and supporting documents were uploaded. The assessee showed substantial compliance, and the Revenue failed to effectively dispute that factual position. Rejection without proper scrutiny of the record was unsustainable, so the matter required fresh examination with a reasonable opportunity of hearing. The rejection order was therefore set aside and the application remitted to the Commissioner for reconsideration in accordance with law and natural justice.

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Issues: Whether the rejection of the assessee's application for registration under section 12AB on the ground of insufficient particulars and documents was justified.

Analysis: The assessee produced material to show that the required particulars and supporting documents had been uploaded during the proceedings, while the Revenue could not effectively controvert that factual assertion. The rejection was found to have been made without proper scrutiny of the record and on an unsustainable assumption of non-compliance. The matter therefore required reconsideration after granting a reasonable opportunity of hearing.

Conclusion: The rejection order was set aside and the matter was remitted to the Commissioner for fresh examination in accordance with law after affording reasonable opportunity to the assessee.

Ratio Decidendi: An application under section 12AB cannot be rejected on a bare or unverified assumption of incomplete disclosure where the record indicates substantial compliance and the matter warrants fresh consideration consistent with natural justice.

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