Assessee-trust is constituted with sole purpose of servicing Indian cows, providing relief and aid and a quality lifestyle to Indian cows, shelters and open land areas for their natural living. Assessee was granted provisional registration under section 12A(1)(ac)(vi)-Subsequently, application filed by assessee under section 12A(1)(ac)(iii) was rejected by Commissioner (E) on ground that there was no proper walls, cover to protect animals, residence of caretakers of animals, place where fodder can be stored, etc. and assessee had not furnished any documentary evidence regarding location of cowshed, name of place or village. On appeal the Tribunal held that   since Commissioner (E) was not satisfied with details/evidence furnished by assessee but assessee was not granted with any other opportunity to meet objections of Commissioner (E), matter is remanded back for de novo adjudication.