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After having noted that the word “document” (used in s. 288(1)) was defined in s. 123(1) to include “a record” which, in turn, was defined to include “any other thing containing information, whether in writing or in any other form ” (her emphasis), she also rejected (at para. 22) the contention of Tellza that “the request for records in an electronically readable format, along with the system administrator’s user ID and password, where applicable, falls outside the scope of the inspection power in the ETA s 288(1).” ...

However, Southcott J accepted the taxpayers’ submissions in this regard by concluding (at para. 111) that “s 231.1 … does not authorize issuance of a demand compelling the recipient to provide, through written answers to questions, substantive information relevant to a taxpayer’s tax position” as contrasted to “authoriz[ing] compulsion of only pre-existing documentation” (para. 79). ...

., Branigan, 2004 FC 245)] …. Southcott J found however that the somewhat detailed affidavit evidence of a CRA manager was sufficient to meet the burden on the Minister to establish service of the s. 231.2(1) requirements, even though the requirements of s. 244(5) had not been met. ...

" See summaries under Treaties – Art. 26A and Art. 25. ...

As reiterated… in Turner … 2012 FCA 159 at para [45]…[w]hen the reviewing court is not in a position to determine if the decision on that point or argument falls within a range of possible, acceptable outcomes which are defensible in respect of the facts and the law, the decision will usually be found to be unreasonable, unless the reviewing court can itself reasonably find that the outcome of the proceedings would not have changed even if the point or argument has been dealt with by the tribunal one way or the other. ...

…[T]echnological obstacles and uncertainties … could readily change from one year to the next. ...

. … …The Applicant chose to collect revenue generated by the machines personally, rather than through his corporation, and he cannot rely upon an accounting principle to ignore the legal reality of the lease and argue that the cost of the lease payments should be attributed to him personally and deductible from his personal income for the 2001 taxation year. …... ...

…The Officer’s literal interpretation tends to frustrate both a purposive construction of section 142 and the intent of the ETA to tax consumption of goods in Canada … [and] appears to lead to a result which is at odds with the equitable underpinnings of subsection 23(2) of the FAA. ...

The failure to do neither, in the Decision itself or the recommendation which preceded it, had the effect, as it appears to me, in the particular circumstances of this case in the context of an application which is essentially an equitable one, of “depriving the process of justification, transparency and intelligibility,” to adopt the expression used in Telfer …. ...

The open court principle allows any person to inspect a court record and any annex "that is available to the public" …. ...