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The factor of space is rele vant upon a consideration of the equity of the double taxation to which profits so earned may be subjected, but it does not, it is submitted, cast any doubt upon the legality of the practice.” 12 * Compare The Gramophone and Typewriter, Ltd. v. ...

Thomson explained part of this purpose that the appellant should dispose of its members’ surplus horses as advantageously as possible for them but the disposal of them was the main consideration. ...

The consideration for the sale was the issue by the purchasing corporation to the vendor, the suppliant company, of the sum of $1,200,000 payable in the fully paid preference stock and common shares of the purchasing corporation, and which stock and Shares were distributed among the shareholders of the suppliant company, four or five in number, I believe, and who alone thereafter held all the stock and shares of the Dominion Distillers Ltd. ...

After due consideration I have reached the conclusion that the contract in suit is governed by the first proviso of section 86, 1(a), that the progress payments therein stipulated fell due and were exigible in the proportion the work progressed and that the sales tax thereon was payable pro tanto at the time such payments fell due and became payable. ...

C.R. 93 at 97; [1953] C.T.C. 203 at 207: “... the true position is that on an appeal to this Court from a decision of the Income Tax Appeal Board, whether the taxpayer or the Minister is the appellant, the assessment under consideration carries with it a presumption of its validity until the taxpayer establishes that it is incorrect either in fact or in law.” ...

It was submitted on behalf of appellant that its claim for a rate of standard profit of 10% was based on the following considerations: " (a) 1940 costs and selling prices for sulphite and groundwood pulp, paper-board, lumber, lath, shingles and ties. ...