In McGurrin v The Champion Publications Ltd 1993 IV ITR 466 it was held that advertising revenue from the publication of newspapers could not arise without sales and the taxpayer was entitled to manufacturing relief in respect of the income from newspaper advertising.
The taxpayer cannot reopen final assessment to backdate a claim for manufacturing relief. Saatchi & Saatchi Advertising Ltd v McGarry (Inspector of Taxes) 1996 V ITR 376
