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It is interesting to note in this connection that the profit which Miller Holdings Limited made on the sale of the lots in the subdivision of 142 acres in the Barker quarter was 26 per cent, which is a further indication of the fact that $40,000 was less than the fair market value of the 60 acre area at the time the appellant turned it over to Miller Holdings Limited. ...

His definition was: “Goodwill is the benefit and advantage of a good name, reputation and connection of a business. ...

In the Appellant Company’s accounts this sum of £25,450 was included as part of the profits from ‘sales in connection with land’. ...

The Company, for the purposes of its undertaking, may (a) erect and maintain docks, dock yards, wharfs, slips and piers at any point on or in connection with its railway, and all the termini thereof, on navigable waters for the convenience and accommodation of vessels and elevators; (b) acquire and work elevators; (c) acquire and run steam and other vessels for cargo and passengers upon any navigable water w hich its railway may connect with; (d) acquire and utilize water and steam power for the purpose of compressing air or generating electricity for lighting, heating or motor purposes, and may dispose of surplus power generated by the Company’s works and not required for the undertaking of the Company; (e) acquire exclusive rights, letters patent, franchises or patent rights and again dispose of the same. 10. ...

As the appellant’s return for the year 1952 was the first of the returns for the three years in question to be filed and the question of liability for penalty under Section 51A of the Income Tax Act, S.C. 1948, c. 52, as amended by S.C. 1950, c. 40, s. 19, arises first in connection with that year, it will be convenient to deal with it first. ...

McDonald expressed the opinion that the appellant’s ownership of shares in Trans-Prairie was of great assistance to it in retaining its underwriting connection. ...

The closing paragraph surely underscores a certain degree of connection between the objects thus ‘‘sold or represented’? ...

Lord Macmillan then discussed the facts of the case before the House and in doing so said at page 441: f‘ It- is important to bear in mind at the outset that the trade of the appellants is to manufacture and deal in margarine, for the nature of a receipt may vary according to the nature of the trade in connection with which it arises. ...

V, page 401, in which the covenant in question did not create any interest in land, and continued: “But the fact that there is some connection with or reference to land does not make a personal contract by A. less a personal contract binding on him, with all the remedies arising thereout, unless the Court can by construction turn it from a personal contract into a limitation of land, and a limitation of land only. ...

The section is merely an enactment conferring upon the Exchequer Court exclusively the jurisprudence of dealing with disputes arising in connection with assessments made under the Act; and as regards tax, interest and penalties, its powers are confined to seeing that they are only charged in strict accordance with the Act. ...