JUDSON, J. (all concur) :—These income tax appeals are the result of re-assessments made by the Minister against the appel- lants for the 1961 taxation year. Their appeals to the Exchequer Court have been dismissed. In my opinion, these further appeals should

JUDSON, J.:—This is an appeal from a judgment of the Exchequer Court which allowed the appeal of the respondent company from its 1951 income tax assessment with costs. The company claimed that it was entitled under Regulation 1201 of the Regulations passed