Natural justice requires meaningful opportunity before rejecting charitable registration and 80G approval for inadequate activity disclosure.

Rejection of charitable registration could not stand where the applicant was not given a meaningful opportunity to furnish specific particulars on the genuineness of its activities, including supporting details sought by the authority. The matter was set aside and remitted for fresh decision after adequate hearing. Refusal of approval under section 80G also failed because it was based on the same incomplete disclosure and the absence of registration, which itself had been remanded. That denial was likewise set aside and sent back for reconsideration on the existing record after proper opportunity to respond. No final determination was made on eligibility.

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Issues: (i) whether the rejection of registration for charitable or exempt status was sustainable when the assessee was not afforded adequate opportunity to furnish further particulars on the genuineness of its activities; (ii) whether the rejection of approval under section 80G could stand when the application was declined for want of specific activity details and consequential absence of registration.

Issue (i): Whether the rejection of registration for charitable or exempt status was sustainable when the assessee was not afforded adequate opportunity to furnish further particulars on the genuineness of its activities.

Analysis: The information originally sought was directed to verification of the genuineness of activities, including details of commencement, trustees, donations, accounts, and supporting material. The assessee's filing was found to be general, but the rejection was made without giving a further effective opportunity to supply the required specific particulars. In such circumstances, the authority ought to have called for additional information before drawing an adverse inference on genuineness.

Conclusion: The rejection was set aside and the matter was restored for fresh decision after granting adequate opportunity of hearing to the assessee.

Issue (ii): Whether the rejection of approval under section 80G could stand when the application was declined for want of specific activity details and consequential absence of registration.

Analysis: The refusal under section 80G rested on the same deficiency in disclosure of actual activities and also on the absence of registration under section 12AA or 12AB. Since the registration issue itself was remanded, the consequential rejection under section 80G could not be sustained on the existing record. The denial was also made without an additional notice or adequate hearing on the specific deficiencies noticed.

Conclusion: The rejection under section 80G was also set aside and remanded for fresh consideration after providing adequate opportunity of hearing.

Final Conclusion: Both matters were remitted to the authority for reconsideration on the merits after due opportunity to the assessee, and no final adjudication on eligibility was made.

Ratio Decidendi: A rejection of registration or approval on the ground of insufficient material cannot be sustained where the applicant is not afforded a meaningful opportunity to furnish the specific particulars called for, and the matter must be reconsidered in accordance with natural justice.

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