Assessee-trust was engaged in providing credit guarantee for loans and advances to new or existing micro and small enterprises or such other enterprises, as may be decided by settlers from time to time. Thus, it was an ameliorating credit guarantee to small ventures and supported the development of businesses/livelihoods. Against such outstanding guarantee, the Assessee created a provision for guarantee claims. As the Assessee was not contravening provisions of S. 2(15) it was entitled to claim exemption under S. 11. It was further held that the deduction claimed by the Assessee under the ‘provision of guarantee claims’ was allowable expenses u/s 37 (1) of the Act. Accordingly, the impugned assessment order rejecting the exemption claimed by the assessee u/s 11 by invoking the provision of Section 2(15) on the ground that the activity of the assessee was contrary to S. 2(15) was to be set aside. (AY.  2019-20)