Taxpayer Forfeiture of Guarantee Money Not Disallowable u/s 37(1) for Rehabilitation Plan Non-Compliance.

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....Allowable expenditure u/s 37 - Guarantee money - in the event assessee is not able to make good the full payment towards R&R plan as directed by CEC, the guarantee money paid by assessee would be forfeited to that extent. We therefore, cannot concur with the observations of the authorities below that such payment is hit by Explanation 1 to Section 37 (1). - AT....