https://www.taxtmi.com/caselaws?id=288691 Lump sum payments made to obtain a head lease and secure an exclusive supply tie through a sublease were treated as capital expenditure, because they were paid once and for all to acquire a leasehold advantage of enduring benefit. The arrangement created a permanent commercial asset in the form of tied retail outlets for a defined term, rather than a mere rebate of trading expenses. Calculation of the amount by reference to estimated gallonage did not alter its true character. On legal form and business substance, the payments were held to be capital in nature and not deductible as revenue expenditure. en-us Mon, 08 Jun 1964 00:00:00 +0530 Mon, 25 Jan 2021 18:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=288691 Lump sum payments made to obtain a head lease and secure an exclusive supply tie through a sublease were treated as capital expenditure, because they were paid once and for all to acquire a leasehold advantage of enduring benefit. The arrangement created a permanent commercial asset in the form of tied retail outlets for a defined term, rather than a mere rebate of trading expenses. Calculation of the amount by reference to estimated gallonage did not alter its true character. On legal form and business substance, the payments were held to be capital in nature and not deductible as revenue expenditure. Case-Laws Income Tax Mon, 08 Jun 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=288691