Delayed registration applications: mandatory time limit, no prior show-cause notice required, and natural justice plea failed.

A delayed application for registration was governed by a mandatory filing time limit, and condonation depended on the applicant showing sufficient cause to the Income-tax Officer's satisfaction. Where the application was admittedly out of time, the burden remained on the applicant to explain the delay, and the officer was not required to issue a prior notice or call for a show-cause explanation before rejecting it. The availability of a revision remedy was treated as an adequate alternative, so the plea based on natural justice failed.

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Issues: Whether, on an application for registration filed beyond the time prescribed, the Income-tax Officer was bound to issue notice and afford an opportunity to show cause before rejecting the application, and whether the assessee could insist on natural justice despite the statutory delay.

Analysis: The statutory scheme made the time limit for filing the application mandatory, while the proviso empowered the Income-tax Officer to condone delay only if sufficient cause was shown to his satisfaction. Where the application was admittedly out of time, the burden lay on the applicant to explain the delay; the officer was not required to call upon the applicant to show cause before rejecting it. The existence of a revision remedy was also treated as an adequate alternative.

Conclusion: No prior opportunity to show cause was required before rejecting the delayed registration application, and the plea of natural justice failed.

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