Search - considered

None of those requests were approved because the assignment of the authority was considered to be invalid. [22]      Beginning in December of 1992, the plaintiff began submitting refund requests pursuant to section 100 of the Act on the ground that the subject goods were rotary valves or parts (also an item on the Minister's List). ...

The Supreme Court of Canada rejected such an inference after having considered extrinsic materials which showed otherwise. ...

The contract is silent on the duty to "repay" in such an eventuality, and given the carefully structured provisions for repayment from the sales of tickets, and the option considered in the next paragraph, I do not think that an obligation to this effect can be implied. [34]      The agreement expressly contemplates the possibility that, after acceptance of the software, Ticketnet might fail to pay to Air Canada five cents for each ticket sold through the software in accordance with the schedule. ...

Downs in the following words:                                   "Having considered the decisions, the writings and the various aspects of the public interest which claim attention, I have come to the conclusion that the Court should state the relevant principle as follows: a document which was produced or brought into existence either with the dominant purpose of its author, or of the person or authority under whose direction, whether particular or general, it was produced or brought into existence, of using it or its contents in order to obtain legal advice or to conduct or aid in the conduct of litigation, at the time of its production in reasonable prospect, should be privileged and excluded from inspection. ...

  [34]            In Gibson v Canada, 2005 FCA 180, 334 NR 288 [Gibson (FCA)] leave to appeal refused: [2005] SCCA 326, which set aside the Court’s decision in Gibson (FC), above, the Federal Court of Appeal considered subsection 222(4) of the ITA. ...

  [42]            She did, however, in paragraph 31 of her affidavit, refer to an August 31, 2010 Directive issued by the Director of Policy Development at CRA Headquarters (CRA-HQ) in Ottawa sent to all Assistant Directors/SR&ED Division at each Tax Services Office which stated as follows: In cases where the tax year is statute-barred, any letter issued by the TSO/TC to the taxpayer denying a [taxpayer requested adjustment] should be worded to ensure that it is not considered a determination or reassessment thus allowing a taxpayer the right to object.  ...

  ¶11      The statutory provisions considered as a whole along with the explicit language in s. 12 of the Tax Court of Canada Act leave no doubt that Parliament has given the Tax Court exclusive jurisdiction to deal with claims arising out of GST assessments and taxpayers’ claims for rebates of GST paid ...

According to section 214 of the PSLRA, a final level grievance decision is considered “final and binding for all purposes of this Act and no further action under this Act may be taken on it”, while subsection 233(1) of the PSLRA states that “every decision of an adjudicator is final and may not be questioned or reviewed in any court” (Hagel v. ...

ATTORNEY GENERAL OF CANADA   INFORMATION COMMISSIONER OF CANADA     MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO, PURSUANT TO RULE 369   REASONS FOR ORDER AND ORDER:   SCOTT J.   ...

Format of the notices of violation [27]            Even though I am dismissing the motion for lack of jurisdiction, I nonetheless considered the applicant’s arguments. ...