The assessee-trust, registered under section 12AA, advanced loans through self-help groups and non-governmental organisations to economically weaker sections while charging interest substantially higher than prevailing market rates. The Tribunal held that the assessee was engaged in organised commercial microfinance activities with the predominant object of earning profit and that its activities were no different from those of commercial financial institutions. In the absence of any real element of charity, the assessee’s activities were hit by the proviso to section 2(15), and it was not entitled to exemption under section 11. (AY. 2013-14).