Section 23(c) of ITA

(c)     any loss or expense, the deduction of which would otherwise be allowable, to the extent to which it is recoverable under any contract of insurance, guarantee, security or indemnity, except where section 23L(3) applies;

[Paragraph (c) substituted by section 24(1) of Act 23 of 2020 effective on 1 January, 2021 and applies in respect of years of assessment commencing on or after that date]