Assessee filed an online application in Form No. 10AB seeking registration under section 12AB. A letter/notice was issued at e-mail/address provided in the application, requiring the assessee to submit certain documents/explanations, but no compliance was made by assessee. Thereafter, a reminder letter was issued vide notice fixing the date of hearing, but no compliance had been made by the assessee. However, one more opportunity was given to the assessee vide letter fixing the date of hearing, but the assessee had not provided any details/documents on this date of hearing. CIT(E)  rejected the provisional registration on the ground that Form 10AB was incomplete, the assessee was registered under the Rajasthan Public Trust Act, 1959, and there was non-genuineness of activities and non-compliance. On appeal before the  Tribunal, the assessee contended that the Trust had already placed on record a certificate of registration under the Public Trust Act, and two other reasons, as mentioned by CIT(E), being curable in nature, the assessee should be provided one more opportunity to adduce the required documents before CIT(E).  Tribunal held that since the dispute required adjudication on merits after affording a proper opportunity of being heard in consonance with principles of natural justice, the matter was to be restored to the file of CIT(E) for fresh adjudication and, in meanwhile, provisional registration shall continue to remain valid till such decision. (AY. 2023-24)