Key legal question
Whether the company car private-use/self-consumption adjustment was lawful
Extracted holding
The cars were also used for non-business purposes; the self-consumption adjustment was therefore justified.
Extracted reasoning
The appellant had no reliable records of vehicle use or costs, the use of two similar business cars was not explained by its business purpose, and the factual findings were not manifestly incorrect. The taxpayer bears the burden of proving the deduction-reducing fact of exclusive business use.