The assessee was a public charitable trust registered under S. 12AA of  the Act . The assessee imported and distributed wattle extracts (which constituted one of the cleaning agents for processing raw hides). The AO denied the exemption and also recommended for cancellation of the registration of the assessee and assessed the assessee as an association of persons. The CIT (A) allowed the appeals filed by the assessee. The Tribunal held that the trading activities engaged in by the assessee were not mentioned in its objectives, that its activities of import of raw material from abroad and distribution of such raw material amounted to commercial transaction and a trading activity which generated profits and denied the exemption under S.  11 to the assessee. On appeal the Court held that  the denial of benefits of tax exemption under S.  11 on the ground that the activities of import and distribution of wattle extracts was commercial in nature within the scope of the provisos to S.  2(15) though the assessee was registered under S.  12A(a) required reconsideration and examination in greater depth by the Tribunal. The findings of the Tribunal were insufficient to reverse the order of the CIT(A ). It was required to take note of the legal position which prevailed at the relevant time. The order passed by the Tribunal was set aside and the matter was to be remanded to it for fresh consideration. Matter remanded.( AY.2009-10 to 2011-12)