Mahoney,
J:—We
are
all
of
the
opinion
that
the
learned
trial
judge
erred
in
law
in
holding
that
Parliament
had
not,
by
subparagraph
18(
l)(l)(i)
of
the
Income
Tax
Act,
clearly
prohibited
the
deduction
of
the
$8,000
in
issue
in
the
computation
of
the
respondent’s
income
for
its
1972
taxation
year.
The
appeal
is
allowed;
the
decision
of
the
Trial
Division
is
set
aside
(except
as
to
costs)
and
the
assessment
of
the
respondent’s
income
tax
for
its
1972
taxation
year
is
restored.
As
agreed
between
the
parties,
the
award
of
costs
in
the
Trial
Division
is
not
disturbed
and
the
respondent
is
entitled
to
its
costs
of
the
appeal
to
be
taxed
as
between
solicitor
and
client.
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