Fair hearing in registration proceedings requires notice and opportunity before rejection; application restored for fresh adjudication.

Rejection of a regular registration application without a show-cause notice or effective hearing was identified as procedurally unsustainable. The stated basis-that provisional registration was invalid because activities began before its grant-was applied without allowing the applicant to explain its activities or respond to that basis. Fair procedure requires an effective opportunity of hearing before deciding the registration application. The rejection was set aside, and the application was restored for fresh adjudication after affording a fair hearing.

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Issues: Whether rejection of the application for regular registration without issuing a show-cause notice and providing a fair opportunity of hearing was sustainable.

Analysis: The application was rejected solely on the premise that the provisional registration was invalid because activities had commenced before its grant. No show-cause notice was issued before rejection, and the assessee was not afforded an opportunity to explain its activities or address the stated basis for rejection. Fair procedure required an effective opportunity before determining the registration application.

Conclusion: The rejection was set aside and the registration application was restored for fresh adjudication after affording a fair opportunity of hearing to the assessee.

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