Held that the  excess interest charged by Bank cannot be said to be an expenditure incurred for the purpose of business.  Disallowance was restricted to the extent of the amount claimed as deduction during the year. However the  disallowance was restricted to the extent of the amount claimed as deduction during the year.  Corporate guarantee commission  allowable as deduction. The fact that the it was converted in to equity share capital by State Government did not change the character of the expenditure.    (AY. 2019-20)