Rav Shmuel Kaminetzky SHLI”TA was matir on Simchas Torah in a year like this year, where Shobbos followed Simchas Torah. In my Chabura in B.M.G. we learnt this sugya for an Elul Zman, and many concluded to be Matir for many different reasons. There is a Rav in Cleveland who says to take a dirty utensil into the shower with you and wash it first, then to go in. If you learnt up the sugya as i have, Rabbi 108300, you will understand that it makes much more sense to be Matir than to be Oser.