Natural justice in section 12A registration: inadequate response time and ignored adjournment led to remand.

Denial of registration under section 12A was held unsustainable where the trust was given less than a week to respond to the show-cause notice and its adjournment request was not considered. The short compliance period was treated as inconsistent with fair procedure and contrary to the principles of natural justice. The matter was therefore remanded to the Commissioner for de novo consideration in accordance with law.

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Issues: Whether denial of registration under section 12A was sustainable when the assessee trust was given a very short time to respond to the show-cause notice and the request for adjournment was not considered, and whether the matter required remand for fresh consideration.

Analysis: The assessee trust had sought registration under section 12A(1)(ac) of the Income-tax Act, 1961. The notice seeking clarification allowed less than one week for compliance, and the subsequent request for adjournment was not addressed before the application was rejected. Such a short compliance window was found to be inconsistent with fair procedure and contrary to the principles of natural justice.

Conclusion: The denial of registration was not sustained on the existing record, and the matter was remanded to the Commissioner for de novo consideration in accordance with law.

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