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SCC

Denison Mines Ltd. v. Minister of National Revenue, 74 DTC 6525, [1974] CTC 737, [1976] 1 S.C.R. 245

One business or commercial principle that has been established for so long that it is almost a rule of law is that “The profits of any transaction in the nature of a sale must, in the ordinary sense, consist of the excess of the price which the vendor obtains on sale over what it cost him to procure and sell, or produce and sell, the article vended …” (See The Scottish North American Trust, Ltd. v. ... Solicitors for the appellant: McCarthy & McCarthy, Toronto. Solicitor for the respondent: D.S. ...   [1] [1972] F.C. 1324. [2] [1971] F.C. 295. ...
SCC

Minister of National Revenue v. Edgeley Farms Limited, [1969] SCR 603

Solicitors for the respondent: Goodman & Carr, Toronto.   [1] [1968] 2 Ex. ...
SCC

Tip Top Tailors Limited v. The Minister of National Revenue, 57 DTC 1232, [1957] CTC 309, [1957] S.C.R. 703

The principle was applied by this Court in Bennett & White v. M.N.R., [1949] S.C.R. 287; [1949] C.T.C. 1, in which certain payments, made as the price of obtaining guarantees required for bank advances to the company, were held to be of a capital nature and not deductible. ... In the circumstances it was held to be of the latter, but in the reasons the following language clearly differentiates the case from that before us: " " Now, it seems to us, having regard to ordinary business and banking experience, that it would be absolutely impossible to dissect the various items in an overdraft account. ... M.N.R., [1944] A.C. 126; [1944] C.T.C. 94, and Bennett & White Construction Co. ...
SCC

R. v. Snider, 54 DTC 1129, [1954] CTC 255 (SCC)

Cammell, Laird & Company, [1942] A.C. 624. When these authorities are closely examined, however, it will be found that they cannot be taken to proceed on any principle so broadly stated, and it becomes necessary, then, to enquire into the nature of testimonial privilege against disclosure and the grounds on which it is made effective in legal proceedings.. ... Its foundation is that the information cannot be disclosed without injury to the public interests and not that the documents are confidential or official; which alone is no reason for their non-production. and by Viscount Simon in Duncan v. Cammell, Laird & Co., [1942] A.C. 624 at 636: “The principle to be applied in every case is that documents otherwise relevant and liable to production must not be produced if the public interest requires that they should be withheld.” ...
SCC

Croydon Management Corporation v. Deputy Minister of Revenue of the Province of Quebec, [1970] SCR 308

Solicitors for the defendant, appellant: Geoffrion & Prud’homme, Montreal. ...   [1] [1960] S.C.R. 619, 24 D.L.R. (2d) 1, 35 W.W.R. 241. [2] [1967] Que. ...
SCC

Trans Mountain Oil Pipe Line Company v. Jasper School District No. 3063, [1958] SCR 349

He finds that, generally, all property within the territorial limits of the school district is liable, subject, among other exemptions not pertinent here, to the exemption of s. 5(1) (p), "Property assessable under The Pipe Line Taxation Act ". ... Both these statutes deal with taxation; and when s. 3(1) of The Pipe Line Taxation Act refers to lines "situated outside of any town" it is concerned with a subject-matter of tax related to physical boundary, a feature to which all taxation of corporeal property is related. ... The tax is on an interest in real property and that is expressly excepted from the operation of the agreement by the language of item 4 of Appendix B containing the Acts or parts of Acts imposing taxes declared not to be corporation taxes, " The Assessment Act, R.S.A. 1942, c. 157, Tax on real and personal property (except section 14)". ...
SCC

P.P.G. Industries Canada Ltd. v. A.G. of Canada, [1976] 2 SCR 739

Solicitors for the appellant, Pilkington Brothers (Canada) Limited: Blake, Cassels & Graydon, Toronto. ...   [1] [1973] F.C. 745. [2] [1972] F.C. 1078. [3] [1915] 2 K.B. 276. ...
SCC

Minister of National Revenue v. Armstrong, [1956] SCR 446

John Hudson & Co. Ltd. 2: That means that each one of us has the task of deciding what the relevant words mean. ... The appellant claims to be entitled to deduct the amount so paid from his income for the year 1950 under the terms of s. 11(1)(j) of The Income Tax Act, which permits the deduction of an amount paid by the taxpayer "pursuant to a decree, order or judgment of a competent tribunal in an action or proceeding for divorce payable on a periodic basis for the maintenance of children of the marriage. ... Solicitors for the respondent: Fasken, Robertson, Aitchison, Pickup & Calvin. 1 [1954] Ex. ...
SCC

Fee et al. v. Bradshaw et al., [1982] 1 SCR 609

. …the criteria for intervening are closely bound up with the concept of ultra vires. ... Solicitors for the appellants: Byers, Casgrain, McNally, Dingle, Benn & Lefebvre, Montreal. ...   [1] Oral reasons from the Bench. ...
SCC

Balstone Farms Limited v. Minister of National Revenue, 68 DTC 5018, [1968] CTC 38, [1968] S.C.R. 205

June 9, 1944 106 $ 4,500.00 Mun. of John LePage Assiniboia II. Dec. 14, 1944 154 $ 2,988.20 North John LePage Kildonan III. May 9, 1945 149.7 $ 6,680.00 Assiniboia Minnie LePage IV. Nov. 19, 1950 403 $12,896.00 North John LePage Kildonan V. ... LePage by having the lands farmed under crop leases.-... In March of 1956 the company decided to sell sufficient land to pay off the debentures and promissory notes. ...

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