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Accepting that the word “appeal” refers to the same type of procedure in all these contexts also accords with the presumption of consistent expression, according to which the legislature is presumed to use language such that the same words have the same meaning both within a statute and across statutes …. ...

., 2001 SCC 56 … at para. 42). The necessary inference to be drawn from the express language of s. 95(2.4)(b) is that Parliament chose not to include a competition element in the financial institution exception. ...

No discretion is afforded the Minister or the Minister’s agents: “They are required to follow [the Act] absolutely, just as taxpayers are also required to obey it as it stands” (Harris …. ...

& Mrs. Duha, Mr. Marr; and a friend of Messrs. Duha and Marr who previously had served on the Duha board. ...

I am not satisfied that the 1975 Regulation can be so construed — it did not alter the primary definition of “gross receipts” in the Act, but merely clarified the method by which a subsidiary, discretionary amount was to be assessed. ...

. … The above cases are not of assistance in the cases at bar, where it is common ground that but for an express statutory provision, the foreign exchange loss would be on capital account because the borrowing was on capital account. ...

. … [I]f an item of property is not relevant to income in a particular year, it does not convert to capital property unless it meets the requirements of ss. 13(7) and 45(1). ...

Brown J essentially indicated that it was reasonable for the CITT to consider that if the gloves were not covered by the specific paragraph dealing with clothing items, they should not be considered to be intended to be included in that heading, stating (at para. 50): It is reasonable to interpret that list item as stating exhaustively its own criteria — meaning, in this case, that if an article of clothing or accessories is to be classified in heading 39.26, it must be made by sewing or sealing sheets of plastic together [which was not the case for the goalie gloves]. ...

. … Neither the wording of the [Copyright] Act, nor the object and purpose of the Act, nor practical necessity support an interpretation of these sections which would place ephemeral recordings within the introductory paragraph to s. 3(1) rather than s. 3(1)(d) [re recording right]. ...

Before concluding that the ARQ had not exceeded its territorial competence in making this requirement, Rowe J found that the sending of the requirement to the Calgary branch (which was deemed to be a separate entity only for the limited purposes of s. 462)) did not detract from the fact that it was sent to a person (the bank) that operated in Quebec, stating (at para. 88): It would be absurd if the procedural requirements imposed by s. 462(2) … were understood to affect the ARQ’s authority to issue a formal demand to a bank that operates within its territorial jurisdiction. ...