1943 (11) TMI 13 - DSC - Income Tax

Summary

Issues:
- Disallowance of deduction for medical expenses incurred due to uncomfortable and dangerous working conditions.
- Deduction of doctor's bills as permissible deductions under general grounds or wear and tear clauses.

Analysis:
The appellant contested the disallowance of a deduction for medical expenses incurred while working in uncomfortable and hazardous conditions, arguing that such expenses should be deductible. Lord Greene, M. R., acknowledged the appellant's grievance but emphasized the need to adhere to the Income Tax Acts. The appellant's argument regarding wear and tear deductions for medical expenses was dismissed as unsustainable. Lord Greene clarified that the taxpayer's body cannot be considered as "plant" subject to wear and tear, and therefore, medical expenses do not fall under this category.

Regarding the deduction of doctor's bills on general grounds, it was determined that such expenses do not qualify as they are not "wholly and exclusively laid out or expended for the purposes of the trade, profession, employment, or vocation." Lord Greene explained that while medical expenses are essential for maintaining health to continue working, they also benefit the taxpayer personally as a human being, making them ineligible for deduction under the Income Tax Acts. Additionally, paragraph (b) of the applicable rule excludes doctor's bills as expenses for maintenance or private purposes distinct from the trade or profession.

In conclusion, the appeal was dismissed by Lord Greene, M. R., with the agreement of Finlay L.J. and Morton L.J. The appellant's contentions were deemed lacking in substance, and the appeal was rejected. Leave to appeal to the House of Lords was also refused, marking the conclusion of the judgment.