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The words of the individual provisions to be applied to the particular case under consideration are then to be read in their grammatical and ordinary sense in the light of the intention of Parliament embodied in the Act as a whole, the object of the Act and the scheme of the Act, and if they are clear and unambiguous and in harmony with that intention, object and scheme and with the general body of the law, that is the end. 3. ...

Relevance will be decided by the judge hearing the underlying application for judicial review on the merits. [42] However, the necessity of disclosing information in the proceedings, as assessed by the Minister when preparing the common record, is a very different consideration. ...

A literal or legalistic interpretation must be avoided when the basic object of the treaty might be defeated or frustrated in so far as the particular item under consideration is concerned. ...

While the collection measures contemplated by the Agency inconvenience and adversely affect the respondents, the tax authority also risks being left empty-handed if these measures are suspended. [69] Other than arguing that they will face irreparable harm if the Minister is not enjoined from pursuing collections, Iristel has not advanced other concrete considerations to be assessed at this stage of the analysis. ...

The Court noted that “a decision to recommend or not to recommend remission is very different from a judicial decision, since it involves a considerable amount of discretion and requires the consideration of multiple factors. ...

I cannot permit the action to continue based only on abstract considerations of fairness. ...

I agree with the respondent, but the Circular provides additional and separate considerations for the Minister’s analysis under the particular subsection at issue. [58] I therefore conclude that the immediate benefits of the applicant’s requests for relief under the two subsections are not identical. ...

There is no doubt that serious consideration was given to this location much earlier though no firm decision may have been taken. ...

While this is one element to consider, the absence of income from the property is not a principal consideration in determining whether it was purchased for development with the secondary intention of reselling at a profit if this could not be accomplished, or as a pure investment. ...

For the purposes of convenience I will now set out the sections of the Act in question: 11. (1) Notwithstanding paragraphs (a), (b) and (h) of subsection (1) of section 12, the following amounts may be deducted in computing the income of a taxpayer for a taxation year: (g) an amount paid by the taxpayer in the year or within 120 days from the end of the year to or under a registered pension fund or plan in respect of services rendered by employees of the taxpayer in the year, subject, however, as follows: (i) in any case where the amount so paid is the aggregate of amounts each of which is identifiable as a specified amount in respect of an individual employee of the taxpayer, the amount deductible under this paragraph in respect of any one such individual employee is the lesser of the amount so specified in respect of that employee or $1,500, and (ii) in any other case, the amount deductible under this paragraph is the lesser of the amount so paid or an amount determined in prescribed manner, not exceeding, however, $1,500 multiplied by the number of employees of the taxpayer in respect of whom the amount so paid by the taxpayer was paid by him, plus such amount as may be deducted as a special contribution under section 76. 76. (1) Where a taxpayer is an employer and has made a special payment in a taxation year on account of an employees’ superannuation or pension fund or plan in respect of past services of employees pursuant to a recom- mendation by a qualified actuary in whose opinion the resources of the fund or plan required to be augmented by an amount not less than the amount of the special payment to ensure that all the obligations of the fund or plan to the employees may be discharged in full and has made the payment so that it is irrevocably vested in or for the fund or plan and the payment has been approved by the Minister on the advice of the Superintendent of Insurance, there may be deducted in computing the income of the taxpayer for the taxation year the amount of the special payment. 139. (1) In this Act, (ahh) “registered pension fund or plan’’ means an employees’ superannuation or pension fund or plan accepted by the Minister for registration for the purposes of this Act in respect of its constitution and operations for the taxation year under consideration; 137. (1) In computing income for the purposes of this Act no deduction may be made in respect of a disbursement or expense made or incurred in respect of a transaction or operation that, if allowed, would unduly or artificially reduce the income. ...