Referencing relevant case law, outline the factors that the Court considers suggests a payment is not deductible under s8-1 ITAA on the basis, it is of a capital nature.

Canmaker Steel Pty Ltd is a metal can manufacturing firm that has operated from the same premises for over ten years. The company is a large business taxpayer with an average annual turnover is $750 million. During the year, the company incurred the following expenses (net of GST). Calculate the maximum income tax deduction available for Canmaker Steel in respect of the payments for the year ended 30 June 2022.

15/8/21	Payment of a $15,000 fine to the Australian Government Environmental Protection Authority for failing to prevent polluted factory wastewater from entering a nearby river.
31/10/21	Re-painting the interior of the administration offices at a cost of $27,000.
31/1/22	Building an extension to the factory to accommodate additional machinery at a cost of $240,000. The extension was operational from 31/1/22.
1/3/22	Borrowing fees of $5,000 in relation to a three-year loan provided by XYZ Bank to build the factory extension.

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