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It is uncontested that, during the years under appeal, Products engaged in no business whatsoever in Canada and the question under section 253 narrows down to a consideration of its activities between April 26, 1965 and the year 1973. ...

Finally the jurisprudence that has developed on the kind of issue we are dealing with requires consideration. ...

As mentioned in the Moldowan decision, although the “quantum element is not a deciding factor”, it is an important one which should be taken into consideration. ...

Counsel for the respondent in his argument says that the key consideration “in this particular case must be what the land could be used for a Valuation Day’’. ...

Our prime consideration was to sell to a reputable party, a builder perferably. ...

Mr Cattanach gives the ratio decidendi: It was determined to be for such services performed by the management personnel in the preceding year to be paid in the year the fund was set up after careful consideration being given by the directors whether the business operations and returns of the prior year justified a fund in the amount determined to be paid in the next ensuing year. ...

All issues must be determined by a careful consideration of all of the relevant evidence both direct and circumstantial. ...

In this way, one must take into consideration the effect of section 28 of the Rules on every subsection in the Act which affects the exempt income of mines. ...

The Appellant submits that the present circumstances parallel those under consideration in the above U.S. decisions. ...

It has not been made clear to me in argument that the apparent absence of these two aspects- so crucial as considerations in Tonn (supra), should be accorded less weight in this matter. ...