Compounding fees to Reserve Bank of India allowed as they aren't for offenses; Section 37(1) Explanation inapplicable.

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....Disallowance towards compounding fees paid by the assessee to the Reserve Bank of India - It is not a case where the assessee has been held to have committed an offence or the amount has been paid for purpose, which was prohibited in law, hence the provisions of Explanation to section 37(1) of the Act are not attracted. - AT....