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TD 93/D236W — Withdrawal - Income tax:(i) does the whole amount receivable by an advertising agency from an advertiser client (for the cost of media space, commission and service fee) form part of the gross income of the agency under subsection 25(1) of the Income Tax Assessment Act 1936? (ii) when is this income 'derived' for the purposes of subsection 25(1) of the Income Tax Assessment Act 1936? (iii) where an advertiser fails to pay an advertising agency for placing an advertisement with a media entity, is the agency entitled to claim a deduction under section 63 of the Income Tax Assessment Act 1936? · Tullian