https://www.taxtmi.com/caselaws?id=184189 The article addresses whether a company may deduct as a trading expense the market premium forgone when issuing shares at par to employees, concluding it is not deductible. It reasons the forgone premium is capital in nature, involves no cash disbursement or diminution of assets, and therefore is not an expense "wholly and exclusively" for the trade. Payments that discharge contractual trading liabilities or actual asset distributions used as remuneration remain deductible, but a non-realised premium on allotment is neither a trading outlay nor deductible; employee taxation of the benefit does not convert the company's non-receipt into a trading deduction. en-us Wed, 08 May 1940 00:00:00 +0530 Fri, 01 Jul 2016 17:18:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184189 The article addresses whether a company may deduct as a trading expense the market premium forgone when issuing shares at par to employees, concluding it is not deductible. It reasons the forgone premium is capital in nature, involves no cash disbursement or diminution of assets, and therefore is not an expense "wholly and exclusively" for the trade. Payments that discharge contractual trading liabilities or actual asset distributions used as remuneration remain deductible, but a non-realised premium on allotment is neither a trading outlay nor deductible; employee taxation of the benefit does not convert the company's non-receipt into a trading deduction. Case-Laws Income Tax Wed, 08 May 1940 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184189