Podium sought deductions of $460,046 for seismic strengthening and $1,517,926 for ground-floor glazing on a mixed-use commercial building in central Hamilton. Under s. DA 2(1) of the Income Tax Act 2007, spending that is capital in nature – money that creates or improves an asset rather than maintaining it – cannot be deducted for income tax. Podium argued that the disputed items were repairs and maintenance and could be separated from the wider building project.