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IT IS FURTHER ORDERED THAT the respondent Minister and everyone under his direction and control be, and he is and they are prohibited from continuing with collection proceedings or actions against the applicant until it is lawful and fair to do — one certain criterion for which being lawful assessment of Part VIII tax actually found and assessed to be owing, upon assessment of tax in regard to applicant’s filed return for its taxation year ended February 28, 1986. ...

., [1968] S.C.R. 140; [1968] C.T.C. 44; 68 D.T.C. 5001, is as follows: “... the production of articles for use from raw or prepared material by giving to these materials new forms, qualities and properties or combinations whether by hand or machinery. ...

.: — Ferme Klosterhos Inc. (Klosterhos) is contesting income tax assessments made by the Minister of National Revenue (the Minister) for the 1988, 1989, 1990 and 1991 taxation years. ...

If so determined, the second issue is whether the reassessment for the 1989 year is statute-barred or does the assessment fall within the provisions of subparagraph 152(4)(«)(i) of the Income Tax Act (the “Acf ’). ...

The expenditures made by the appellant for treating, during the taxation period in question, were $4,206.40, shown in its books as "" treating expenses,'' or "‘treating at hotels,’’ while its disbursements for advertising otherwise were $331.29 for the same period, its total sales for the period being $154,000. ...

. ^86(1) There shall be imposed, levied and collected a consumption or sales tax of eight per cent on the sale price of all goods, — "‘(a) produced or manufactured in Canada, payable by the producer or manufacturer at the time of the delivery of such goods to the purchaser thereof. ...

The statement therein contained was as follows: " In' compliance with the expressed wish of the annuitant, the date of maturity of this contract is hereby changed from March 24, 1954, to March 24, 1947. ...

More precisely, having regard to the submissions of the parties, did each transaction give rise to an exempt supply as regards the Appellants. [57] Certain general provisions of the Goods and Services Tax portion of the Excise Tax Act should be kept in mind. [58] Section 165 enacts that every recipient of a taxable supply made in Canada shall pay to the Government of Canada tax in respect of the supply equal to 7 % of the value of the consideration for the supply, unless it is a zero-rated supply. [59] The definitions of certain terms and expressions of general import used in section 165 or elsewhere in the Excise Tax Act should be noted. ... "Alban Garon" J.T.C.C. [1]               Page 23b of the transcript, line 24 to page 24, line 12. [2]               Section 7 quoted above and referred to at the hearing of these appeals was amended by section 88, c. 10 of the Statutes of Canada, 1997 and was made retroactive to September 14, 1992 for certain purposes. ...

The usual rule — and I see no reason why it should not apply in income tax appeals — is set out in Odgers’ Principles of Pleading and Practice, 2nd edition at page 532: The “burden of proof” is the duty which lies on a party to establish his case. ...

The doctrine laid down in Salomon v Salomon & Co, Ltd ([1897] AC 22; [1895-99] All ER Rep 33) has to be watched very carefully. ... This “sue for and recover” rule was followed in Re J Bibby & Sons, Ltd Pensions Trust Deed, Davies v IRC, [1952] 2 All ER 483. ... The principle of Salomon v Salomon & Co Ltd, supra, is still very much part of our law and in general the courts have rigidly applied it. ...