Expenditure incurred to implement a contractual closure of a...

Expenditure incurred to implement a contractual closure of a business undertaking is not deductible under section 37(1), as that provision requires expenditure wholly and exclusively incurred for carrying on business rather than bringing an undertaking to an end. Common management of the closed and continuing divisions does not satisfy this requirement; the closure-payment disallowance was therefore restored. Foreign exchange fluctuation on imports must be determined from actual liabilities under individual transactions where book figures are available. As the fluctuation on capital goods had been capitalised and the claimed loss related to spares and consumables, with no contrary Revenue evidence, the estimated disallowance was unsustainable and its deletion was upheld.