Brulé,
T.C.J.:—This
is
an
appeal
from
reassessments
relating
to
the
appellant's
1980,
1981
and
1982
taxation
years
in
which
the
respondent
added
amounts
to
income
in
1980
of
$24,800,
in
1981
of
$25,688,
and
by
disallowing
a
deduction
in
1982
of
$1,000.
At
the
outset
of
the
hearing
the
appellant
abandoned
the
appeal
with
respect
to
the
1982
taxation
year.
Issue
The
sole
issue
in
question
is
whether
or
not
a
loan
made
by
the
appellant's
employer
qualified
as
an
"excluded
loan"
within
the
meaning
of
paragraph
80.4(2)(a)
of
the
Income
Tax
Act
during
the
years
in
question.
The
answer
turns
on
the
interpretation
of
the
meaning
of
the
term
"excluded
loan”
as
found
in
this
paragraph.
Facts
While
there
is
no
dispute
over
the
facts
in
this
case,
for
purposes
of
understanding
the
problem,
it
may
be
helpful
to
summarize
them
as
partially
set
out
in
the
notice
of
appeal:
The
Appellant
at
all
relevant
times
was
an
officer
and
employee
of
Triarch
Corporation
Limited
("Triarch")
and
continues
to
be
an
officer
and
employee
of
Triarch.
In
1977
the
Appellant
agreed
to
participate
in
Triarch's
Employee
Share
Purchase
Plan
(the
"Plan").
Under
the
Plan,
Triarch
loaned
the
Appellant
$250,000
and
the
Appellant
used
the
said
amount
of
$250,000
to
acquire
beneficial
ownership
of
1,106
shares
of
Triarch.
In
connection
with
the
loan,
the
Appellant
delivered
his
promissory
note
to
Triarch
in
principal
amount
of
$250,000
and
bearing
interest
at
8%
per
annum.
In
1979,
the
Triarch
shares
were
transferred
by
the
Appellant
to
De
Wattville
Holdings
Inc.
“De
Wattville”),
the
Appellant's
family
holding
company,
and
an
election
was
made
under
subsection
85(1)
of
the
Income
Tax
Act
(the
"Act")
in
connection
with
the
transfer.
All
of
the
issued
shares
of
De
Wattville
were
at
all
relevant
times
owned
by
the
Appellant
and
members
of
his
family.
The
appellant
paid
interest
on
the
loan
until
January
of
1980
when
the
company
decided
to
eliminate
such
payment.
After
the
period
in
question
the
loan
was
repaid.
Appellant's
Position
Counsel
for
the
appellant
argued
that
the
transfer
of
the
shares
to
De
Wattville
in
1979
did
not
have
the
effect
of
disqualifying
the
loan
as
an
"excluded
loan"
within
the
meaning
of
paragraph
80.4(2)(a)
of
the
Act.
Counsel
stated
that
the
appellant
took
out
the
loan
in
good
faith
and,
at
that
time,
had
no
intention
of
selling
or
transferring
the
shares.
The
appellant
could
not
independently
transfer
his
shares
as
Triarch
was
a
private
corporation.
Permission
for
the
transfer
of
shares
to
De
Wattville
was
granted
for
income
and
estate
planning
purposes.
It
is
the
appellant's
submission
that,
because
the
loan
qualified
as
an
excluded
loan
at
the
time
it
was
made,
the
subsequent
transfer
of
shares
could
not
change
the
purpose
or
status
of
the
loan.
Respondent's
Position
Counsel
for
the
respondent
submitted
that
Parliament's
intention
in
adopting
section
80.4
was
to
allow
the
employee
a
tax-free
benefit
only
as
long
as
he
held
the
shares.
This
intention
is
revealed
by
the
use
of
the
words
"to
be
held
by
him”
found
in
subsection
80.4(2),
with
respect
to
shares
purchased
with
the
borrowed
funds.
The
transfer
of
the
shares
to
De
Wattville
would
remove
the
loan
form
the
scope
of
the
tax-free
benefits
defined
in
subsection
80.4(2).
Analysis
Subsection
80.4(1)
of
the
Act
provides
that
the
employee
who
receives
an
interest-free
loan
by
virtue
of
his
employment
is
deemed
to
have
received
a
benefit
equal
to
the
prescribed
interest
rate.
An
exception
is
provided
for
in
the
case
of
"excluded
loans".
Subparagraph
80.4(2)(a)(i)
of
the
Act
as
it
applies
to
the
taxation
years
in
question
defines
"excluded
loans"
as
follows:
80.4
(2)
For
the
purposes
of
this
section,
(a)
"excluded
loan”
means
(i)
the
portion
of
any
loan
described
in
paragraph
(1)(a)
made
to
an
officer
or
employee
of
a
corporation
to
enable
or
assist
him
to
purchase
fully
paid
shares
of
the
capital
stock
of
the
corporation
or
of
a
corporation
related
to
it
to
be
held
by
him
for
his
own
benefit,
.
.
.
There
is
no
question
that,
when
the
loan
was
made,
it
fell
within
the
definition
of
"excluded
loan”.
The
Court
must
now
decide
if
the
subsequent
transfer
of
the
shares
form
the
appellant
to
the
De
Wattville
corporation
in
1979,
removed
the
loan
form
the
excluded
category
for
the
taxation
years
in
question,
therefore,
adding
a
taxable
benefit
to
the
appellant's
income
pursuant
to
subsection
80.4(1)
of
the
Act.
The
decision
turns
on
the
construction
to
be
given
to
the
words
"to
be
held
by
him
for
his
own
benefit”
in
subparagraph
80.4(2)(a)(i)
of
the
Act.
If
these
words
are
taken
to
mean
that
the
shares
must
be
held
by
the
taxpayer
form
the
time
the
loan
is
made
to
the
time
it
is
repaid,
the
test
will
be
applied
for
every
taxation
year.
In
the
event
the
taxpayer
no
longer
holds
the
shares
the
loan
will
cease
to
qualify
as
an
excluded
loan
and
deemed
interest
will
be
added
to
the
taxpayer's
income.
Another
possible
construction
of
the
subsection
is
that
the
loan's
status
in
respect
of
the
definition
of
"excluded
loan”
is
determined
once
and
for
all
at
the
time
the
funds
are
advanced
to
the
taxpayer.
If
at
that
time
the
loan
qualifies
as
an
"excluded
loan”
it
will
retain
its
character
regardless
of
the
taxpayer's
subsequent
disposition
of
the
shares.
The
principles
that
must
guide
the
Court
in
the
construction
of
tax
statutes
have
been
stated
by
Estey,
J.
in
the
case
of
Stubart
Investments
Limited
v.
The
Queen,
[1984]
C.T.C.
294
at
316;
84
D.T.C.
6305
at
6323:
Courts
today
apply
to
this
statute
the
plain
meaning
rule,
but
in
a
substantive
sense
so
that
if
a
taxpayer
is
within
the
spirit
of
the
charge,
he
may
be
held
liable.
See
Whiteman
and
Wheatcroft,
supra,
at
37.
While
not
directing
his
observations
exclusively
to
taxing
statutes,
the
learned
author
of
'Construction
of
Statutes’,
2nd
ed.,
(1983),
at
p.
87,
E.A.
Driedger,
put
the
modern
rule
succinctly:
Today
there
is
only
one
principle
or
approach,
namely,
the
words
of
an
Act
are
to
be
read
in
their
entire
context
and
in
their
grammatical
and
ordinary
sense
harmoniously
with
the
scheme
of
the
Act,
the
object
of
the
Act,
and
the
intention
of
Parliament.
The
Supreme
Court
of
Oregon
had
the
following
comments
on
the
plain
meaning
of
the
word
“held”,
in
the
case
of
Holman
Transfer
Co.
v.
City
of
Portland,
250
P.
2d
929
at
930:
[The
plaintiffs]
.
.
.
now
shift
their
ground
to
the
word
"held",
and
assert
that
the
Supreme
Court
of
Iowa
erred
in
holding
in
Starr
v.
Case,
59
Iowa
491,13
N.W.
645,
647,
that“Participles
have
no
reference
to
time”,
and
that
we
erred
in
following
the
Iowa
court.
Welch,
as
quoted
by
the
Iowa
court,
said:
"Participles
have
no
reference
to
time,
they
simply
show
the
action,
being
or
state
of
the
verb
form
which
they
are
derived
as
finished
or
unfinished.”
Webster
defines
a
participle
as
“A
word
that
partakes
of
the
nature
of
both
verb
and
adjective;
a
verbal
adjective,
modifying
a
noun,
but
sharing
the
adjuncts
and
construction
of
the
verb
from
which
it
is
derived.”
We
believe
that
there
is
no
difference
among
the
authorities
on
grammar
as
to
the
correctness
of
this
definition.
A
careful
reading
of
the
statute
reveals
that
there
is
no
time
frame
to
which
the
expression
"to
be
held"
may
be
related
to,
other
than
the
time
the
loan
is
made.
The
grammatical
and
ordinary
sense
of
the
definition
would
therefore
indicate
that
at
the
time
spoken
of
in
the
Act,
that
is
the
time
the
loan
is
made,
the
shares
purchased
are
to
be
held
by
the
taxpayer.
The
omission
in
the
definition
of
any
other
reference
to
the
time
at
which
the
shares
are
to
be
held,
such
as
"at
the
end
of
the
taxation
year”
or
“until
full
repayment
of
the
loan",
such
would
be
an
indication
of
the
legislator's
intention.
The
examination
of
similar
dispositions
would
support
this
conclusion.
Subparagraphs
15(2)(a)(iii)
and
80.4(2)(a)(i)
of
the
Act
contain
substantially
the
same
wording.
Both
these
subparagraphs
reproduce
the
wording
found
in
the
Canada
Corporations
Act
R.S.C.
1970,
c.
C-32.
Although
the
Canada
Corporations
Act
prohibits
loans
by
corporations
to
shareholders
or
directors,
paragraph
17(2)(d)
of
that
Act
provides:
17(2)
Nothing
in
this
section
shall
be
taken
to
prohibit
(d)
the
making
by
a
company
of
loans
to
persons,
other
than
directors,
bona
fide
in
the
employment
of
the
company,
with
a
view
to
enabling
those
persons
to
purchase
fully
paid
shares
in
the
capital
stock
of
the
company,
to
be
held
by
themselves
by
way
of
beneficial
ownership;
or.
.
.
As
illustrated
by
the
Supreme
Court
of
Canada
case
of
Jones
and
Maheux
v.
Gamache,
[1969]
S.C.R.
119;
7
D.L.R.
(3d)
316,
identical
expressions
used
by
Parliament
in
different
Acts
are
deemed
to
carry
the
same
meaning
and
are
therefore
to
be
construed
in
the
same
way.
This
would
seem
particularly
true
of
subparagraph
80.4(2)(a)(i)
of
the
Income
Tax
Act
and
paragraph
17(2)(d)
of
the
Canada
Corporations
Act
as
both
subparagraph
and
paragraphs
constitute
exceptions;
one
to
the
taxation
of
the
benefit
conferred
by
an
interest-free
loan,
the
other
to
the
prohibition
of
loans
to
directors
of
the
corporation.
It
is
obvious
that
Parliament
intended
the
status
of
loans
in
respect
of
paragraph
17(2)(d)
of
the
Canada
Corporations
Act
to
be
determined
once,
at
the
time
of
the
loan
and
that
the
subsequent
transfer
of
shares
was
not
to
remove
the
loan
from
the
scope
of
the
exception
of
paragraph
17(2)(d).
It
was
not
the
legislator's
intent
in
so
wording
the
provision,
to
require
the
shares
to
be
held
for
a
definite
amount
of
time,
and
that
is
made
clear
by
subsection
17(4)
of
the
Canada
Corporations
Act
which
holds
the
officers
of
the
company
liable
for
prohibited
loans.
If
the
subsequent
transfer
of
shares
would
have
the
effect
of
removing
the
loan
from
the
scope
of
the
exception
of
paragraph
17(2)(d)
of
the
Canada
Corporations
Act,
the
loan
would
become
a
prohibited
loan,
one
for
which
the
officers
of
the
corporation
could
be
held
liable.
Surely
this
cannot
be
said
to
be
Parliament's
intent.
The
same
construction
should
be
given
to
subparagraph
80.4(2)(a)(i)
of
the
Income
Tax
Act.
The
subsequent
transfer
of
shares
by
the
taxpayer
should
not
be
construed
as
transforming
a
loan
made
for
a
purpose
described
in
the
subparagraph
into
a
loan
made
for
another
purpose.
In
arriving
at
that
conclusion
the
Court
has
considered
the
decision
rendered
in
Emile
Morin
v.
M.N.R.,
26
Tax
A.B.C.
161;
61
D.T.C.
161.
The
issue
in
that
case
was
whether
the
taxpayer
was
bound
to
include
in
his
income
the
loan
made
to
him
by
the
corporation
of
which
he
was
the
president
and
principal
shareholder.
The
loan
had
been
made
to
enable
the
taxpayer
to
purchase
a
house
close
to
his
new
work
location.
The
taxpayer
purchased
the
house
in
question
but
because
of
unforeseen
events
did
not
occupy
it.
Because
of
problems
encountered
in
selling
the
house
the
taxpayer
rented
it
out
for
the
entire
tax
year.
The
Income
Tax
Act
as
it
applied
to
the
taxation
years
in
question
contained
the
following
provision:
8.
(2)
Where
a
corporation
has,
in
a
taxation
year,
made
a
loan
to
a
shareholder,
the
amount
thereof
shall
be
deemed
to
have
been
received
by
the
shareholder
as
a
dividend
in
the
year
unless
(a)
the
loan
was
made
(ii)
to
an
officer
or
servant
of
the
corporation
to
enable
or
assist
him
to
purchase
or
erect
a
dwelling
house
for
his
own
occupation,
The
Tax
Appeal
Board
decided
the
loan
received
by
the
shareholder
fell
within
the
exception
dealing
with
housing
loans
even
though
the
house
was
never
occupied
by
the
taxpayer.
Mr.
M.
Boisvert
of
the
Tax
Appeal
Board
stated
at
173
(D.T.C.
165)
in
the
Morin
case
(supra):
It
was
not
what
happened
after
the
action
took
place
which
counts
the
most,
but
rather
what
the
situation
was
when
it
took
place.
It
may
be
that
events
subsequent
to
a
certain
occurence
have
to
be
examined
in
order
to
evaluate
the
good
faith
of
a
taxpayer
and
check
the
veracity
of
his
statements.
In
the
present
case,
however,
to
contend
that
events
subsequent
to
the
loan,
which
could
not
be
foreseen
at
the
time,
should
change
the
interpretation
to
be
given
to
section
8(2)(a)(ii)
of
the
Act
(quoted
above)
would
be
to
give
that
section
a
strictness
which
it
does
not
possess.
The
same
reasoning
could
be
applied
to
excluded
loans
under
subparagraph
80.4(2)(a)(i)
of
the
Act.
A
conclusive
argument
for
the
appellant’s
construction
of
subparagraph
80.4(2)(a)(i)
of
the
Act
is
found
in
the
French
version
of
the
provision.
Section
133
of
the
British
North
America
Act,
as
it
has
been
interpreted
by
the
Supreme
Court
in
The
Queen
v.
Dubois,
[1935]
S.C.R.
378,
recognizes
the
official
status
of
both
the
French
and
English
versions
of
a
statute.
Paragraph
18(1)
of
The
Constitution
Act,
1982
states
unequivocally:
18(1)
The
statutes,
records
and
journals
of
Parliament
shall
be
printed
and
published
in
English
and
French
and
both
language
versions
are
equally
authoritative.
This
principle
has
been
expounded
by
Parliament
in
section
8
of
the
Official
Languages
Act,
R.S.C.
1970,
chap.
0-2
which
reads
as
follows:
8.
(1)
In
construing
an
enactment,
both
its
versions
in
the
official
languages
are
equally
authentic.
(2)
In
applying
subsection
(1)
to
the
construction
of
an
enactment,
(a)
where
it
is
alleged
or
appears
that
the
two
versions
of
the
enactment
differ
in
their
meaning,
regard
shall
be
had
to
both
its
versions
so
that,
subject
to
paragraph
(c),
the
like
effect
is
given
to
the
enactment
in
every
part
of
Canada
in
which
the
enactment
is
intended
to
apply,
unless
a
contrary
intent
is
explicitly
or
implicitly
evident;
(b)
subject
to
paragraph
(c),
where
in
the
enactment
there
is
a
reference
to
a
concept,
matter
or
thing
the
reference
shall,
in
its
expression
in
each
version
of
the
enactment,
be
construed
as
a
reference
to
the
concept,
matter
or
thing
to
which
in
its
expression
in
both
versions
of
the
enactment
the
reference
is
apt;
(c)
where
a
concept,
matter
or
thing
in
its
expression
in
one
version
of
the
enactment
is
incompatible
with
the
legal
system
or
institutions
of
a
part
of
Canada
in
which
the
enactment
is
intended
to
apply
but
in
its
expression
in
the
other
version
of
the
enactment
is
compatible
therewith,
a
reference
in
the
enactment
to
the
concept,
matter
or
thing
shall,
as
the
enactment
applies
to
that
part
of
Canada,
be
construed
as
a
reference
to
the
concept,
matter
or
thing
in
its
expression
in
that
version
of
the
enactment
that
is
compatible
therewith;
and
(d)
if
the
two
versions
of
the
enactment
differ
in
a
manner
not
coming
within
paragraph
(c),
preference
shall
be
given
to
the
version
thereof
that,
according
to
the
true
spirit,
intent
and
meaning
of
the
enactment,
best
ensures
the
attainment
of
its
objects.
The
French
version
of
paragraph
80.4(2)(a)
of
the
Act
as
it
applied
to
the
taxation
years
in
question
reads
in
part
as
follows:
80.4
(2)
Aux
fins
du
présent
article,
(a)
"prêt
exclu”
désigne
(i)
la
partie
de
tout
prêt
visé
à
l'alinéa
(1)(a)
consenti
à
un
cadre
ou
à
un
employé
d'une
corporation
pour
lui
permettre
d'acheter,
à
titre
personnel
et
pour
son
propre
bénéfice,
des
actions
entièrement
libérées
du
capital-
actions
de
la
corporation
ou
d'une
corporation
liée
à
cette
dernière,
The
words
“loan
made
.
.
.
to
enable
.
.
.
to
purchase
.
..
shares
.
.
.
to
be
held
by
him
for
his
own
benefit”
become
in
the
French
version
"prêt.
.
.
consenti
.
.
.
pour
.
.
.
permettre
d'acheter,
à
titre
personnel
et
pour
son
propre
bénéfice”.
The
ambiguity
created
in
the
English
version
by
the
words
"to
be
held
by
him
for
his
own
benefit”
is
not
present
in
the
French
version
were
the
words
"à
titre
personnel
et
pour
son
propre
bénéfice"
are
used.
The
construction
requiring
the
shares
to
be
held
for
the
duration
of
the
loan
cannot
be
supported
by
the
French
text.
The
proper
construction
of
the
French
version
of
subparagraph
80.4(2)(a)(i),
one
which
is
consistent
with
the
grammatical
and
ordinary
sense
of
the
words
is
given
in
the
following
commentary
by
Mr.
M.F.
Ménard
in
his
article:
Options
d'achat
d'actions
et
prêts
aux
actionnaires,
found
in
Congrès
“80”,
Association
Québécoise
de
Planification
Fiscale
et
successorale,
Montréal,
1981,
p.
405
to
435
at
page
426:
Les
conditions
à
être
remplies
sont
les
suivantes:
—
les
actions
devront
être
acquises
par
l'employé
lui-même,
pour
son
bénéfice
personnel;
—
les
actions
acquises
doivent
être
des
actions
entièrement
libérées,
le
prêt
ne
pouvant
prendre
la
forme
d’une
balance
sur
souscription
d'actions.
Il
ne
semble
pas
nécessaire
que
les
actions
ainsi
achetées
restent
la
propriété
de
l'employé
jusqu'au
remboursement
du
prêt.
La
condition
qui
est
posée
par
l'article
15(2)
L.I.R.
(Loi
de
l'impôt
sur
le
revenu)
est
que
les
actions
achetées
le
soient
pour
le
bénéfice
personnel
de
l'employé
au
moment
où
le
prêt
est
consenti.
[Translation]
The
conditions
that
must
be
met
are
the
following:
—
the
shares
must
be
purchased
by
the
employee
personally,
for
his
own
benefit;
—
the
purchased
shares
must
be
fully
paid,
the
loan
cannot
consist
of
the
remaining
balance
of
a
share
subscription.
It
seems
unnecessary
that
such
shares
remain
the
property
of
the
employee
until
the
loan
is
repaid.
The
condition
provided
by
subsection
15(2)
I.T.A.
(Income
Tax
Act)
is
that
the
shares
purchased
be
for
the
personal
benefit
of
the
employee
at
the
time
the
loan
is
made.
Although
the
commentary
deals
with
subsection
15(2)
of
the
Act,
because
of
the
similarities
of
the
provisions,
it
applies
as
well
to
subparagraph
80.4(2)(a)(i).
In
his
book,
Construing
Bilingual
Legislation
in
Canada,
Butterworths,
Toronto,
1981
at
page
125,
Mr.
Beaupré
analyses
the
relevant
jurisprudence
and
concludes
that
where,
as
in
the
present
case,
there
are
two
possible
constructions
of
a
statute,
the
construction
common
to
both
versions
will
prevail
unless
it
is
subject
to
objection
when
the
provision
so
construed
is
read
within
its
total
context.
If
the
construction
common
to
both
languages
is
subject
to
objection,
the
construction
consistent
with
the
purpose
of
the
section
of
the
Act
will
be
prefered
even
though
it
has
no
possible
analogue
in
the
other
language
version.
The
author
explains
the
rule
of
construction
as
follows:
In
other
words,
even
though
as
an
initial
step
in
the
interpretation
of
an
ambiguous
provision,
a
construction
is
found
that
is
common
to
both
the
English
and
French
versions,
that
construction
must
be
related
back
to
and
tested
against
the
entire
context
of
the
‘provision
before
being
settled
upon.
Such
was
the
conclusion
drawn
from
the
cases
of
Food
Machinery
Corporation
v.
The
Registrar
of
Trade
Marks,
Ville
de
Montreal
v.
ILGWU
Center
Inc.
and
most
importantly,
of
The
Queen
v.
Compagnie
Immobilière
BCN
Ltée.
Construing
Bilingual
Legislation
in
Canada
(supra)
p.
125.
As
indicated
by
the
author,
this
rule
of
construction
may
be
inferred
from
the
comments
made
by
Pratte,
J.
in
the
case
of
The
Queen
v.
Compagnie
Immobilière
BCN
Limitée,
[1979]
1
S.C.R.
865
at
871;
[1979]
C.T.C.
71
at
75:
I
do
not
believe
that
paragraph
8(2)(b)
of
the
Official
Languages
Act
is
of
much
assistance
to
respondent.
The
rule
therein
expressed
is
a
guide;
it
is
one
of
several
aids
to
be
used
in
the
construction
of
a
statute
so
as
to
arrive
at
the
meaning
which,
"according
to
the
true
spirit,
intent
and
meaning
of
an
enactment,
best
ensures
the
attainment
of
its
objects"
(paragraph
8(2)(d)).
The
rule
of
paragraph
8(2)(b)
should
not
be
given
such
an
absolute
effect
that
it
would
necessarily
override
all
other
canons
of
construction.
In
my
view
therefore
the
narrower
meaning
of
one
of
the
two
versions
should
not
be
preferred
where
such
meaning
would
clearly
run
contrary
to
the
intent
of
the
legislation
and
would
consequently
tend
to
defeat
rather
than
assist
the
attainment
of
its
objects.
The
Court
feels
that
the
construction
of
subparagraph
80.4(2)(a)(i)
most
consistent
with
the
words
of
the
Act
read
in
their
grammatical
and
ordinary
sense,
is
the
one
that
is
common
to
both
language
versions.
It
does
not
allow
a
loan
that
falls
within
the
definition
of
“excluded
loan”
at
the
time
of
the
granting
of
the
loan
to
be
later
removed
from
that
category.
The
provision
so
construed,
when
read
in
the
context
of
the
entire
Act
is
in
no
way
subject
to
objection.
The
respondent
has
adduced
no
evidence
to
show
that
such
a
construction
is
contrary
to
Parliament's
intent.
Examination
of
similar
provisions
reveals
the
appellant's
construction
is
consistent
with
this
intent.
It
must
again
be
pointed
out
that
the
evidence
has
shown
that
the
loan
and
subsequent
transfer
of
shares
to
De
Wattville
were
in
no
way
part
of
a
sham.
The
appellant
purchased
the
shares
in
good
faith
and
at
that
time
had
no
intention
of
selling
or
transferring
them.
For
these
reasons,
the
appeal
in
respect
of
the
1980
and
1981
taxation
years
is
allowed,
with
costs,
and
the
matter
referred
back
to
the
Minister
for
reconsideration
and
reassessment.
It
is
further
ordered
and
adjudged
that
the
appeal
in
respect
of
the
1982
taxation
year
is
hereby
dismissed.
Appeal
allowed
in
part.
Email this Content