https://www.taxtmi.com/caselaws?id=55399 The article explains the distinction between lease premium and advance rent: where a lump sum is paid before execution of a long-term lease, described in the deed as premium and shown by the covenants to secure an enduring advantage, it is treated as capital in nature rather than revenue expenditure. Applying the substance-over-form principle, the majority view denied year-by-year deduction of the amount claimed. A dissent considered the payment to be advance rent spread over the lease term and therefore deductible annually. en-us Sat, 16 May 1981 00:00:00 +0530 Fri, 26 Nov 2010 18:11:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55399 The article explains the distinction between lease premium and advance rent: where a lump sum is paid before execution of a long-term lease, described in the deed as premium and shown by the covenants to secure an enduring advantage, it is treated as capital in nature rather than revenue expenditure. Applying the substance-over-form principle, the majority view denied year-by-year deduction of the amount claimed. A dissent considered the payment to be advance rent spread over the lease term and therefore deductible annually. Case-Laws Income Tax Sat, 16 May 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55399