Hugessen,
J.A.:—
We
are
all
of
the
view
that
the
learned
trial
judge
reached
the
correct
result.
The
appellant
would
have
us
read
subsection
13(7.1)
of
the
Income
Tax
Act,
R.S.C.
1952,
c.
148
(am.
S.C.
1970-71-72,
c.
63)
(the
"Act"),
as
it
read
at
the
relevant
time
(1980),
as
though
the
words
"has
deducted”
and
''deducted"
referred
to
the
moment
at
which
the
computation
was
actually
made,
that
is
to
say
after
the
end
of
the
taxation
year
in
respect
of
which
it
was
made.
Such
an
interpretation
would
not
only
be
contrary
to
the
whole
scheme
of
the
Act,
but
would
also
be
irreconcilable
with
other
parts
of
the
Act,
as
for
example
paragraph
12(1)(t)
.
On
their
ordinary
meaning
the
words
"has
deducted"
and
'^deducted"
in
subsection
13(7.1)
refer
to
operations
effected
in
respect
of
the
taxation
year
to
which
those
deductions
were
applied,
notwithstanding
that
the
actual
mathematical
operations
themselves
may
have
taken
place
at
a
subsequent
time.
The
appeal
will
be
dismissed
with
costs.
Appeal
dismissed.
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