Joel Theatrical Rigging Contractors – Tax Court of Canada finds that solving a challenge by trial and error likely does not qualify as SR&ED

Although this likely was implicit in other cases, Sommerfeldt J explicitly found that the trial and error method (i.e., trying thing after thing after thing until something works, rather than testing against an hypothesis) was likely inconsistent with the scientific method, so that such work likely does not qualify as SR&ED. (The projects before him failed for a host of reasons.)

Neal Armstrong. Summary of Joel Theatrical Rigging Contractors (1980) Ltd. v. The Queen, 2017 TCC 6 under s. 248(1) - scientific research and experimental development.