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Allowable expenditure u/s 37(1) - addition relating to form fees which was deposited for obtaining the wine shop through government - non-accepting the theory of commercial expediency - assessee has made multiple applications for lottery to obtaining the wine shop licence and for that he has made 20 application of each 15,000/- the payment has been made by banking channel. - The Tribunal found that the expenses were incurred to increase the chances of obtaining the license through a lottery system and were non-refundable. Therefore, the expenses were deemed allowable deductions u/s 37(1) of the Act. - Additions directed to be deleted.