Commentary on Sections Overview Overview Section 147: Deduction for capital expenditure
571.This section provides for a deduction for certain capital expenditure incurred by the trader or a predecessor. It is based on section 91 of ICTA. The corresponding rule for income tax is in section 170 of ITTOIA.
572.Section 91 of ICTA refers to “land” in a cemetery or crematorium. Subsection (1) refers instead to “an interest in” such land. This accommodates better the possibility that operators of cemeteries and crematoria might sometimes hold land in leasehold rather than in freehold form.