The Port Elizabeth Electric Tramway Case: Is the Meaning Ascribed to the Phrase “In the Production of the Income” By Watermeyer AJP in the Port Elizabeth Electric Tramway Case Still Religiously Followed Today?

This article analyses the meaning attributed to the phrase “in the production of the income” as used in the present section 11(a) of the Income Tax Act, which provides for general expenses to be allowed as deductions against income. Read together with section 23(g), section 11(a) is commonly referred to as the “general deduction formula”. It has been said that the meaning ascribed to the phrase by Watermeyer AJP (as he was then) in his judgment in the Port Elizabeth Electric Tramway Company Ltd v CIR is “too mechanical and contrived”. Consequently, the judiciary, in applying the meaning as attributed to it by Watermeyer AJP in subsequent cases, has sometimes led to inconsistent and conflicting judgments. In fact, the application of the meaning so ascribed takes no account of the economic and other non-economic realities of doing business in the 21st century. The main objective of this article has been to re-ignite the debate surrounding Watermeyer AJP’s interpretation of the phrase, “in the production of the income”, in the Port Electric Tramway case and in so doing establish whether the narrow meaning ascribed by him to that phrase has subtly been changed and widened by the judiciary in subsequent cases. It can be concluded from an analysis of the case law discussed in this article that Watermeyer AJP’s interpretation, if strictly adhered to, can and does lead to absurd results.However, it is submitted that sanity has finally prevailed. The Supreme Court of Appeal in the comparatively recently decided cases of C:SARS v Mobile Telephone Networks Holdings (Pty) Ltd and Warner Lambert SA (Pty) Ltd v C:SARS, have considerably widened the ambit of expenses that may now be claimed in terms of section 11(a) of the Income Tax Act. The deduction of expenditure as was allowed in those two cases by the Supreme Court of Appeal, would appear not to have been permissible in terms of Watermayer AJP’s interpretation of the meaning of the phrase “in the production of income”. It is submitted that the economic realities of doing business in South Africa in the 21st century are now taken into account in determining whether a business expense falls within the ambit of the phrase “incurred in the production of the income”.Keywords: Section 11(a) of the Income Tax Act, “In the Production of the Income”, “Close Connection”, “Necessary Concomitant”, “Ordinary Operations”, “Remoteness”, Negligenc

The new face of alternative assessment in accounting sciences - technology as an anthropomorphic stakeholder

Worldwide, more and more higher education institutions are making use of online or distance education, due to the increasing demand for tertiary education. In this article, the problem addressed relates to the importance of technology as a stakeholder in alternative assessments for undergraduate accounting sciences modules in an online, non-venue-based, technology-enhanced environment. The purpose of this article is to demonstrate how technology, due to its importance and impact, acts similarly as a human stakeholder and should be treated as an anthropomorphic stakeholder in an online technology-enhanced environment, considering its powerful role. A qualitative approach was followed, and action research was used to develop a conceptual framework. This conceptual framework demonstrates how stakeholder theory could ensure the legitimacy of qualifications through identity verification of students in an online environment through improved performance and innovation potential. These findings contribute to the body of knowledge and due to its importance, technology could be considered as an anthropomorphic stakeholder in the creation, improvement, or restructuring of assessments at online educational institutions

Renormalization of the Deuteron with One Pion Exchange

We analyze the deuteron bound state through the One Pion Exchange Potential. We pay attention to the short distance peculiar singularity structure of the bound state wave functions in coordinate space and the elimination of short distance ambiguities by selecting the regular solution at the origin. We determine the so far elusive amplitude of the converging exponential solutions at the origin. All bound state deuteron properties can then be uniquely deduced from the deuteron binding energy, the pion-nucleon coupling constant and pion mass. This generates correlations among deuteron properties. Scattering phase shifts and low energy parameters in the 3S1-3D1 channel are constructed by requiring orthogonality of the positive energy states to the deuteron bound state, yielding an energy independent combination of boundary conditions. We also analyze from the viewpoint of short distance boundary conditions the weak binding regime on the light of long distance perturbation theory and discuss the approach to the chiral limit.Comment: 22 pages, 11 figure

The role of treatment delays in surgical site infection after appendicectomy in a South African rural regional hospital

Background. Delays to surgery for acute appendicitis in low- and middle-income countries lead to significant morbidity.Objectives. To investigate the role of time to surgery in the development of complicated appendicitis and surgical site infection (SSI) in a rural referral hospital in South Africa (SA).Methods. A prospective cohort study was conducted of all patients presenting to a regional hospital in SA with acute appendicitis during 2017. Inpatient interview and data collection were followed by 30-day post-surgical follow-up to assess time periods to surgery and operative outcomes.Results. A total of 188 patients underwent surgery for acute appendicitis. The median (interquartile range (IQR)) age was 19 (3 - 73) years, and 62% were male. The median (IQR) time from symptoms to surgery was 60 (42 - 86) hours and from hospital admission to surgery 8 (4 - 16) hours. Forty-one percent were managed laparoscopically, 62% had complicated appendicitis, and 25% developed SSI. Time from symptoms to surgery >72 hours was associated with an increased risk of complicated appendicitis (odds ratio (OR) 4.32; 95% confidence interval (CI) 1.36 - 13.75; p=0.013). Patients with SSI had an increased median delay of 15 hours (p=0.05) compared with those without SSI. Multivariable analysis showed that the risk of SSI increased with complicated appendicitis (OR 8.96; 95% CI 2.73 - 29.41; p<0,001) and decreased with laparoscopic surgery (OR 0.21; 95% CI 0.07 - 0.59; p=0.003). Time to surgery had no effect on the risk of SSI in adjusted analyses.Conclusions. Delays to surgery beyond 72 hours significantly increased complicated appendicitis, an important risk factor for SSI. Access to facilities with surgical capability and the use of laparoscopic surgery are modifiable risk factors for SSI

The Chondrocranium of the Mexican Burrowing Toad, \u3cem\u3eRhinophrynus dorsalis\u3c/em\u3e

The chondrocranium of Rhinophrynus dorsalis is described and illustrated. Autapomorphies of R. dorsalis are the presence of the symplectic cartilage and a cartilaginous process on the ascending process of the palatoquadrate. Synapomorphies of Rhinophrynus shared with the Pipidae are: (1) early formation of the lower jaw and (2) presence of a suprarostral plate. Alternative developmental pathways for the formation of the suprarostral plate are considered. Histological data indicates that the suprarostral plate forms from: (1) the early fusion of the cornua trabeculae with the suprarostral cartilages, (2) an anterior growth of the ethmold plate, and (3) subsequent fusion of the cornua trabeculae and the anterior process of the ethmoid plate. The larval crista parotica of R. dorsalis resembles the one described for microhylid taxa

Development of the Suprarostral Plate of Pipoid Frogs

The rostral region of nonpipoid tadpoles has two sets of cartilages, the cornua trabeculae and the suprarostral cartilages, whereas the rostral region in pipoid larvae is occupied by a single and continuous cartilage, the suprarostral plate. The homology of this region in pipoid and nonpipoids tadpoles has been controversial. We examined the early formation and development of the suprarostral plate using serially cross-sectioned specimens of Rhinophrynus, Xenopus, and Hymenochirus. We conclude that the cartilaginous structures present in the rostral area of pipoid and nonpipoid larvae are homologous. Furthermore, we found two different developmental patterns among pipoid larvae. The chondrocranium of Hymenochirus boettgeri is described and illustrated to understand its developmental pattern and because of its uniqueness among pipoid chondrocrania

Permutation Coding with Injections for Modified PAM System

Arriving at a good combination of coding andmodulation schemes that can achieve good error correctionconstitutes a challenge in digital communication systems. In thiswork, we explore the combination of permutation coding (PC)and pulse amplitude modulation (PAM) for mitigating channelerrors in the presence of background noise and jitter. Since PAMis characterised with bi-polar constellations, Euclidean distance isa good choice for predicting the performance of such coded modulationsetup. In order to address certain challenges facing PCs,we therefore introduce injections in the coding system, togetherwith a modified form of PAM system. This modification entailsconstraining the PAM constellations to the size of the codeword’ssymbol. The results obtained demonstrate the strength of themodified coded PAM system over the conventional PC codedPAM system

Permutation Coding with Injections for Modified PAM System

Arriving at a good combination of coding andmodulation schemes that can achieve good error correctionconstitutes a challenge in digital communication systems. In thiswork, we explore the combination of permutation coding (PC)and pulse amplitude modulation (PAM) for mitigating channelerrors in the presence of background noise and jitter. Since PAMis characterised with bi-polar constellations, Euclidean distance isa good choice for predicting the performance of such coded modulationsetup. In order to address certain challenges facing PCs,we therefore introduce injections in the coding system, togetherwith a modified form of PAM system. This modification entailsconstraining the PAM constellations to the size of the codeword’ssymbol. The results obtained demonstrate the strength of themodified coded PAM system over the conventional PC codedPAM system

Frequency optimization for narrowband power-line communications

Abstract: Optimized frequency tones for the power line channel is presented from an experimental scenario. Four sets of frequency tones, grouped according to CENELEC’s regulation on frequency use for narrow band power line applications are selected according to their signal-to-noise ratio (SNR) performance. COMBLOCKS, a prototyping hardware was used for the implementation. Often times, M-FSK/OFDM have been presented and used as the modulation scheme of choice for power line communications (PLC), the choice of best frequencies to use is however, an area that has hardly been explored. This paper is concentrated on the choice of such optimal frequencies