20 Dec 2006
THE COMMISSIONER OF INLAND REVENUE v. FRANCO TONG SUI LUN
- Citation
- THE COMMISSIONER OF INLAND REVENUE v. FRANCO TONG SUI LUN
- Court
- Court of First Instance
- Case number
- HCIA2/2006
The Court held that indemnity repayments were contingent personal contractual obligations not incurred 'in the performance' of the taxpayer's duties within the narrow meaning of s.12(1)(a); therefore they were not 'wholly, exclusively and necessarily incurred' for salaries tax purposes and the Board of Review's allowance of the deductions was set aside.