D BANK LTD v ZIMBABWE REVENUE AUTHORITY 2015 (1) ZLR 176 (H)

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Revenue and public finance — income tax — assessment — previous ruling on $\epsilon$ similar subject — when revenue authority bound by such ruling — ruling based on error of law — authority not bound

Revenue and public finance — income tax — gross income — deductions — $\delta$ expenditure for purpose of trade or production of income — distinction from capital expenditure — expenditure with enduring benefit — acquisition of computer software to run bank's accounts — expectation that system would be in use for some years — such expenditure constituting capital expenditure and not deductible from gross income

Revenue and public finance — income tax — gross income — gain arising from $\epsilon$ use of capital — distinction between fixed and floating capital — gain arising from floating capital constituting gain of revenue nature, not capital nature

Revenue and public finance — income tax — gross income — grant — distinction $\epsilon$ from loan — whether monies received by taxpayer constitute grant or loan — ostensible loan agreement — when can be treated as simulation