In sentencing for 'drug rip-off' supply offences under the DMT Act, the absence of any outlay (no upstream supplier, no cost for the substance) means the entirety of anticipated proceeds would be profit, and this may properly be treated as an aggravating factor of financial gain under s.21A(2)(o) Crimes (Sentencing Procedure) Act 1999 without constituting double counting. The decision in Kalpaxis remains confined to its exceptional facts and provides no general assistance in drug rip-off sentencing.
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