The Appellant Company carried on business as butchers and meat retailers, the number of their shops varying between 1,447 in 1911 and 804 in 1922. It was shown that it was the Company’s policy to close shops or to open shops in accordance with the needs of their business as a whole, and that it was advantageous to dispose of the fixtures and fittings in a shop given up rather than to transfer them to a newly acquired shop. In such circumstances the Company debited in their trading account the difference between the cost of new fixtures and the price obtained for old fixtures, and these items had been added back in computing the Company’s liability to Income Tax and Corporation Profits Tax.
Held: that no deduction was admissible in computing the Company’s profits in respect of the excess of the cost of new fixtures over the price obtained for the old fixtures.
[1928] UKHL TC – 14 – 218
Bailii
England and Wales
Income Tax
Updated: 13 January 2022; Ref: scu.646295
