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. … [T]he sole remuneration which was paid to Mr. Castonguay in 2010 or 2011 was not an “amount paid in addition that which is due.” ...

. … Too many of the expenses incurred in making the sales were missing for it to be possible to state that Oldcastle realized a profit on the sale…. ...

. … [T]he treatment accorded to other productions does not create legitimate expectations for the respondent. ...

. … Nothing in this case justifies a different decision [than in BBM]. ...

In finding that the appellant had continued to be a “registrant,” so that ss. 171(3) and 200(2) did not apply, Favreau J referenced s. 141.1(3) and stated (at paras 57- 60, TaxInterpretations translation): The sale of equipment following the cessation of normal daily activities is … part of what the ETA terms "commercial activity". ...

. … Advisory CIP significantly expands the quantity of relevant evidence that is denied to the courts. ...

. … Words and Phrases credit note ...

However 15 months later, CRA vacated the s. 55(2) assessment of 8231 for reasons that are not explained – so that the only outstanding s. 55(2) assessments were of the corporations (807 and 810) acquired by the purchasers. ...

. … If by issuing no definition, the result was, as the Appeal Division held, that the claim of exemption failed it would mean that by the simple expedient of not making use of the defining power, the Minister could make his decisions unassailable. ...

After finding (at para. 45) that “subsection 3(h) is ultra vires in so far as it applies to alcoholic beverages,” and in concluding that the respondent was entitled to a rebate based on the 19% rate if tax actually imposed rather than the 8.1% rate in s. 3(h), Noël J.A. stated (at para. 68): The purpose of the Act in this case is … clear. ...