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If that had been the case, there would have existed the necessary “mutuality” so that Her Majesty would have had the right of set-off claimed [6] $ and this appeal would have to be dismissed. ... Rapid Data Systems & Equipment Limited (hereinafter referred to as “Rapid Data’’) is “in the business of manufacturing electronic calculators’’. b. ... If they are remitted to someone other than the owner, the owner has no right to them. 10 t Compare N W Robbie & Co Ltd v Witney Warehouse Co Ltd, [1963] 3 All ER 613. ...

Canada, [1987] 2 C.T.C. 206, 87 D.T.C. 5415; Hillsdale Golf & Country Club Inc. v. ... Minister of National Health & Welfare, (1988) 19 C.P.R. (3d) 374. ... Minister of National Health & Welfare (1988), 19 C.P.R. (3d) 374 (EC.T.D.). ...

.), 30 & 31 Victoria, c. 3 91. It shall be lawful for the Queen, by and with the advice and consent of the Senate and House of Commons, to make laws for the peace, order, and good government of Canada, in relation to all matters not coming within the classes of subjects by this Act assigned exclusively to the legislatures of the provinces; and for greater certainty, but not so as to restrict the generality of the foregoing terms of this section, it is hereby declared that (notwithstanding anything in this Act) the exclusive legislative authority of the Parliament of Canada extends to all matters coming within the classes of subjects next hereinafter enumerated; that is to say, 3. the raising of money by any mode or system of taxation. ...

.: — In spite of the very able argument of Mr. Greene, we have not been persuaded that the judgment of the Trial Division was ill-founded. ...

.: — We have not been persuaded that the learned trial judge has committed any error that would require the intervention of this Court. ...

.: — This is an appeal from a judgment of the Tax Court of Canada, dated 16 April, 1996, dismissing the appellant’s appeal from reassessments made under the Income Tax Act (the “Act”) for the taxation years ending 31 December, 1989, 1990 and 1991. ...

.: — This application has been heard at the same time as the application in court file A426/95. ...

.: — This is an appeal from a decision of the Tax Court of Canada dated December 31, 1993 which dismissed the appellant taxpayer’s appeal from a reassessment of income tax for the 1986 taxation year. ...

Notwithstanding that the order in question may be viewed as a procedural ruling (Saint John Shipbuilding & Dry Dock Co. v. ...

His essential and overall finding that the agreement was not a mere “stand still agreement” or an “agreement merely not to pursue,” as contended by counsel, but rather a final one, that was meant to “settle the matter” definitely “a finding that involved, not only a careful analysis of the wording of the agreement and the inter-relation of its various clauses, but also an assessment of the intention of the parties drawn from the factual circumstances and their statements at trial ” cannot be reviewed by us without compelling reasons. ...