No deduction is available in respect of a purely notional item of expenditure as in such cases, an expense has not actually been incurred. In Niddrie and Benhar Coal Co1, the company sold its coal wagons to a railway company, the wagons to be reserved for the exclusive use of the coal company in carrying coal by rail. A claim for demurrage was made by the railway company yearly, but it was never accepted or paid by the coal company. Many years later the old agreement was cancelled, together with the accumulated demurrage claim, and a new agreement was made. The coal company claimed a deduction for a fraction of the demurrage figure on the basis that the old agreement had been valuable to it and the
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