https://www.taxtmi.com/caselaws?id=289500 Legal and accountancy expenses incurred in contesting an excess profits tax assessment were treated as non-deductible trading expenses because they were not laid out wholly and exclusively for the purposes of the trade. The majority view was that such expenditure was directed at reducing or determining tax payable on profits already earned, rather than at earning those profits. The 1939 provision allowing excess profits tax itself to be deducted for income-tax purposes did not extend to the costs of disputing that tax. An asserted additional business motive, such as retaining a key manager, did not change the immediate purpose of the spending. The appeals accordingly failed. en-us Wed, 14 Jul 1948 00:00:00 +0530 Tue, 04 Aug 2020 11:43:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289500 Legal and accountancy expenses incurred in contesting an excess profits tax assessment were treated as non-deductible trading expenses because they were not laid out wholly and exclusively for the purposes of the trade. The majority view was that such expenditure was directed at reducing or determining tax payable on profits already earned, rather than at earning those profits. The 1939 provision allowing excess profits tax itself to be deducted for income-tax purposes did not extend to the costs of disputing that tax. An asserted additional business motive, such as retaining a key manager, did not change the immediate purpose of the spending. The appeals accordingly failed. Case-Laws Income Tax Wed, 14 Jul 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289500