Expenses must be wholly and exclusively incurred in the generation of income to be deductible. Treatment of Capital Expenses- Section 15 and 16 of the Income Tax Act

The Tribunal further found that the Appellant was unable to provide receipts that tallied with the total expense claimed in the audited accounts. Therefore, there was no evidence to show that the amounts as per the audited accounts was wholly and exclusively incurred in the generation of income. The sample receipts that were provided were of capital nature and hence disallowed as per Section 16 of the ITA.