In order to carry on its objective more effectively  the assessee promoted another non-profit organization ( Broadcast Audience Research Council ) (BARC) under section 25 of the Companies Act , 1956 with the object of the conducting market research and studies using appropriate research methodologies with a view to provide accurate , up to date and relevant findings relating to audience of television , in a completely transparent and objective manner. The assessee subscribed its shares and became one of the share holders of the said company  . The AO invoked the provision of section 13(1) (d) of the Act and denied the exemption under section 11 and 12 of the Act . In appeal CIT (A) allowed the claim of the assessee. On appeal by the revenue the Tribunal held that since the assessee did not intend to earn any profits / dividends but held the shares with the sole object to carry on its objectively  , the activity of holding shares by the assessee cannot per se termed as investment and the assessee cannot be said to have committed any violation within the meaning of the provisions of section 11(5)  r.w .s 13(1)(d) of the Act . Appeal of the revenue was dismissed .   ( ITA No. 4193 /4194 / Del/ 2017 dt 14 -9 2020 ) ( AY. 2013 -14 , 2014 -15)