Minister of National Revenue v. Shofar Investment Corporation, 79 DTC 5347, [1979] CTC 433, [1980] 1 SCR 350 -- text
Martland, J:—The question in issue in this appeal is as to whether or not subsection (3) of section 12 of the Income Tax Act, RSC 1952, c 148, has any application in the assessment of income tax payable by the respondent