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Lazarowitz, so that this firm had existed no longer than six or seven months when, on July 24 of that same year it ‘‘... offered to purchase from Messrs. ... Another paragraph, the third of this private agreement, proposed an over-all price of “... ... More in line still with the issue at bar was a pronouncement by Rowlatt, J., in Jesse Robinson & Sons v. ...

& M. Holdings Inc. which acquired the above-mentioned property owned by their mother. ... & M. Holdings Inc. through the purchase of his brother’s shareholdings therein and shortly thereafter the name of the company was changed to Mansfield Holdings Inc. ... & M. Holdings Inc.—acquire the said lane property. The purchase was effected by four notarial deeds of sale which were signed in February and March 1955. ...

When acquired by the appellant, the British patent was subject to a licensing agreement made in 1933 by the parent corporation with 0 & S Bearings Limited, the benefit of which was also transferred to the appellant. ... Following the agreement of 1933, shipments of material, equipment and machinery were made from time to time to 0 & S Bearings Limited by the parent corporation, but there is no clear evidence that any shipment pursuant to the contract was ever made by the appellant, or that any shipment was made by anyone in 1957. ... The first agreement of June 3, 1937, recites the granting of a sole and exclusive licence, and goes on to say that: *.... it is witnessed that in consideration of the royalties hereinafter reserved and of the mutual promises of the parties hereto, the owners agree...’ ...

Staveley Cord & Iron Co., [1928] 2 K.B. 405. "‘Now this being the test to be applied in such cases as the present, it is obvious that the question whether an expenditure made once and for all is or is not to be treated as chargeable to capital and not revenue is one of fact only. ... Considerable reliance was placed by counsel for the respondent on the case of Ward & Co. v. ... Any other course upon the part of its board of directors would have been unusual and would, no doubt, have subjected them to well founded criticism by its stockholders. ’ This case was cited with approval by the Circuit Court of Appeals, Second Circuit, in the case of Nat’l Outdoor Advertising Bureau v. ...

In connection with these contracts, respondent paid the following amounts, during 1953, to: Sigma-Vog-Les Films Marceau $ 12,500 Maroc Films 8,900 Sodak International Films Inc. 210,000 The appellant seeks to recover from the respondent the “withholding” tax of 10% stipulated in Section 106(2) of the Income Tax Act (R.S.C. 1952, c. 148), amounting to $23,100, for which the respondent was re-assessed on February 6, 1957, consequent upon its omission of complying with this alleged obligation. ... Vous vous engagez à mettre en exploitation le film au plus tard le — après l’obtention du visa de censure. 3°) Vous vous engagez à nous fournir le 20 de chaque mois: a) Un bordereau récapitulatif des contrats signés, mentionnant, pour chaque établissement, le pourcentage de location ou le forfait, le minimum garanti, la date limite d’exécution; b) Un bordereau détaillé par salle, des encaissements, mentionnant: le nom de la ville, la date de passage, la recette nette, le pourcentage de location appliqué, le montant de la facturation... c) Un relevé du compte mensuel tenu séparément pour le film. ... Notwithstanding the mention, in exhibits 9 and 10, of the term “cession”, currently associated with notions of sale, the purport of the transaction, a grant of cinematographic reproduction rights for a five-year period at global prices of, respectively, $3,500 and $5,000, undoubtedly fall in the classification of ‘ income from the lease of motion picture films”. ...

C.R. 312; [1959] C.T.C. 308, and Huston & Whitehead v. M.N.R., [1962] Ex. ... If this were not so, subsection (3) of Section 57 would be of little practical value because, under it, the period in respect of which interest is payable commences not earlier than ‘ ‘the day when the overpayment arose’’. ... The appeal is dismissed with costs. 1 * All relevant amendments were made prior to the taxation year in question, being the 1963 taxation year. ...

The ‘‘ Renfrew shares’’ above referred to are shares in Renfrew Petroleums Ltd. and it is not disputed that they had a value at all relevant times of $10,000. ... It reads as follows: “Settlement between Bowman Barron & Diamond. 1. ... Renfrew belongs to Barron & Diamond alone 4. Octave in 3 equal shares 5. ...

., said: " I am quite willing to admit that the intention to exempt must be expressed in clear unambiguous language; that taxation is the rule and exemption the exception, and therefore to be strictly construed;’ The rule may be expressed in a somewhat different way with specific reference to the Income War Tax Act. ... He submits, however, that by use of the words "‘as required by this Part” Parliament intended only that the returns for the ‘‘ preceding years’’ should be in the prescribed form and contain the prescribed information, and that if the returns were filed at any time prior to the date of filing the election to average, the requirements of the section would have been met. ... He submits that as the words which I have underlined were not carried forward into the Income Tax Act and as the words in question are merely " 1 as required’’ and not "‘as and when required’’, or words to that effect, Parliament could not in the later Act have intended to make prompt filing a condition precedent to obtaining the benefit of the section. ...

Fields & Co.—to know where the appellant was engaged at all times. ... Fields & Co. from March, 1945, to the end of that year. She occupied a part of the appellant’s office and did such office work as he required her to do. ... Fields & Co.— gave evidence on behalf of the respondent. He was employed by that firm throughout the whole year 1945 and stated that he had a duty to know where the appellant was from time to time. ...

” This statement is not denied by the two inspectors who were called as witnesses. ... & W. 633 and pages 646 at 650; 150 E.R. 1298, Knutson v. Bourkes Syndicate, [1941] S.C.R. 419; 3 D.L.R. 593, The Municipality of the City and County of St. ... Silverberg’s evidence that it was Morris ’ responsibility to make decisions concerning the payment of the tax in question and that Mr. ...