Assessee NPCI was incorporated under section 25 of the Companies Act, 1956. Promoter banks were mere subscriber to assessee’s share capital and not entities who made substantial contribution of exceeding Rs.50,000 in assessee entity. Clearing functions of RBI were divested to assessee with emergence of PSS, Act 2007.  Electronic payment infrastructure created by assessee would enable a larger section of society to enjoy unparelled secure and convenient payment systems.  Systems being developed by assessee would bring down cost of clearing transactions which would ultimately benefit public at large availing banking services.  Greater penetration of e-payments would encourage larger participation of citizen in banking system and help in meeting larger objective of cashless economy. Tribunal held that  since primary objective of assessee was to administer payment settlement system for larger benefit of general public and not to run clearing system in a commercial manner or on a commercial basis, assessee’s activities were not hit by proviso to section 2(15) of the Act.and since the asseee is engaged in providing technology intensive infrastructure facilities at national level and would obviously require funds to meet operational cost which would necessitate charging of fees by assessee and certain surplus was generated, said fact alone, would not disentitle assessee to claim exemption under sections 11 and 12 of the Act. Further since facilities/services being provided by assessee were uniformly available to user of system against same fee and no concession in fee was given to promoter entities and it could not be said that assessee directly or indirectly applied its income for benefit of persons as specified in section 13(3) of the Act.