Before going on to find that a substantial lump sum contribution by the taxpayer to an employee pension plan was a non-deductible expenditure, Viscount Cave found that its deduction was not prohibited by the prohibition against the deduction of expenses not "wholly and exclusively laid out or expended for the purposes of such trade" (p. 212):
A sum of money expended, not of necessity and with a view to a direct and immediate benefit to the trade, but voluntarily and on the grounds of commercial expediency, and in order indirectly to facilitate the carrying on of the business, may yet be expended wholly and exclusively for the purposes of the trade ... [T]he payment was made for the sound commercial purpose of enabling the company to retain the services of existing and future members of their staff and of increasing the efficiency of the staff... .