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ONCA decision

County of Lambton v. Village of Point Edward., [1942] CTC 183

It would appear from the inclusion of the two resolutions in the one report that the Committee considered that so long as it retained the figure of $30,084,500, for the aggregate, it was permissible to alter at will the several sums appropriated to the local municipalities that went to make up that aggregate. ...
SCC

Kerr v. Superintendent of Income Tax and Attorneygeneral for Alberta, [1943] CTC 97

The Alberta Act is phrased differently from those considered in the two decisions referred to but, upon consideration, I have concluded that the former should, for the purposes of this appeal, be construed in the manner already indicated. ...
QCQC decision

City of Montreal v. O’sullivan College of Business, [1945] CTC 39

It is clear also that it was considered a special tax by the Legislature itself because in the same article of the charter authorizing the imposition of this tax there is a further paragraph permitting imposition of "‘an additional special tax’’ on departmental shops. ...
EC decision

His Majesty the King v. Weddel Limited, [1945] CTC 245

At page 185, he said: We cannot be aware of all the reasons that moved the Minister and, in any event, his jurisdiction under section 98 was dependent only upon his judgment that the goods were sold at a price which was less,—not, be it noted, less than what would be a fair price commercially or in view of competition or the lack of it,—but less than what he considered was the fair price on which the taxes should be imposed. ...
SCC

Roderick W.S. Johnston v. Minister of National Revenue, [1948] CTC 195, [1946-1948] DTC 1182

In my view the statement referred to in sec. 60, ss. 2, is not to be considered otherwise than as an argument: it is clearly not evidence. ...
SCC

The Minister of National Revenue v. The National Trust Company, Limited,, [1948] CTC 339

In this case a statement was filed by the executors and in accordance with section 22, the Minister assessed the duties he considered to be payable under the Act (including the item in question) and sent a notice of such assessment to the executors. ...
TCC

0808414 B.C. Ltd. v. The King, 2024 TCC 99

Spiro DATE OF JUDGMENT: July 24, 2024 APPEARANCES:   Counsel for the Appellant: Clifford Rand, Josh Kumar, and Monica Carinci Counsel for the Respondent: Lindsay Tohn and Linsey Rains   COUNSEL OF RECORD: For the Appellant: Name: Clifford Rand, Josh Kumar, and Monica Carinci   Firm: Aird & Berlis LLP Toronto, Ontario   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     [1] Logical relevance is the first of four “ Mohan factors” to be considered in determining the admissibility of expert opinion evidence. ...
TCC

M.N.R. v. Gold Line Telemanagement Inc., 2024 TCC 119

By excluding the expert report in its entirety presently, the Court risks depriving itself of: the complete evidentiary record that should be considered, and/or the necessary technical or scientific basis to come to a conclusion; or both, in the adjudication of Parts I and II of the Application. [19] However, the jurisprudence, and not the Rules, drives the analysis of whether or not to grant the Minister’s Motion. ...
TCC

Sim v. The King, 2025 TCC 22

This indicates that the power to seek production under section 86 is limited to documents, which would be considered relevant at trial. ...
FCTD

Canada (National Revenue) v. Ne'eman Foundation Canada, 2025 FC 670

At that latter stage, the Court will review all the evidence on record and ask itself whether, on the whole of the evidence submitted by the parties, there are reasonable grounds to be believe that the collection of any part of the assessment amount would be jeopardized by delay. [23] When reviewing a Jeopardy Order, “[t]he judge shall determine the question summarily and may confirm, set aside or vary the authorization and make such other order as the judge considered appropriate” (Robarts at para 4). ...

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