One of the lines of attack advanced by the then Inland Revenue in the Ensign Tankers case was that, since the taxpayer (through the partnership by which it acquired the master print of the film) had from its own resources contributed 25 per cent of the expenditure on the print (funding the balance of its investment by non-recourse borrowing), it had ‘incurred’ only that 25 per cent amount as expenditure on the provision of the plant.

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