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Desautels in his initial application and considered the first officer’s notes, as well as all the documents filed by the applicant. ... Desautels suffered a drop in income of more than 50% in the last 12 months, since, in the absence of a bank statement, it is impossible to determine whether he received eligible income. [52] In my view, the record shows that the second officer considered all the documents and information Mr. ... Desautels’ supporting documents and having considered the parties’ arguments, I conclude, for all of the foregoing reasons, that the second officer’s decision is reasonable. ...

The Officer considered all documentation submitted by the Applicant and determined it insufficient to support the Applicant’s eligibility for the benefits. ... Further, the Applicant was advised by letter dated July 25, 2022 that disability benefits were not considered employment or self-employment income. [29] In light of the limited information provided by the Applicant to support that she had earned $5,000 in employment income as required by legislation, I cannot find the Officer’s decisions unreasonable. ... This was not, however, a reason advanced by the Officer for determining that the Applicant was ineligible for the benefits and, therefore, was not considered by the Court: Beddows v Canada (Attorney General), 2023 FC 919 at para 128. [32] Finally, the Applicant raises a new issue before this Court, namely that she had a total reported income of $8,501 in the 2021 taxation year: Applicant’s Memorandum of Fact and Law at para 12. ...

Grandmont is of the opinion that the evidence and arguments she sent to the CRA were misinterpreted, unfairly considered inadmissible, and taken out of context. ... Here, the Officer expressly considered the comments and documentary evidence submitted by Ms. ... Grandmont’s case, the record shows that the Officer followed rational, coherent and logical reasoning in her analysis, and that she considered Ms. ...

Although the purchase price was considered adequate Mr David Friedman, who was sixty-four years old at the time, and his brother Hyman, who I understand was older, did not accept the condition by which the twenty-year lease would be personally secured. by the appellants. ... Counsel for the appellants, on the other hand, is asking that the Board find that the offer to purchase the subject property at a price of $1,500,000, dated October 22, 1971, (Exhibit A-1) be considered as indicative of the fair market value of the property as at December 31, 1971. ... Since the offer to purchase the property in 1971 was made by an informed purchaser, it is logical to suppose that the prospective buyer considered that the replacement cost of the property was $1,500,000. ...

Perhaps it could be considered that the amounts were rather arbitrary, particularly in that they were specifically geared to pay a mortgage payment on his personal residence. ... Obviously, there is no definition in the Circular for small amounts, and whether or not the payments in question can be considered small amounts, it’s not up to us to determine that. ... Consequently, in this case, Mrs Latta has included one third of the lease payment in her income on her T4 slip as a taxable benefit, which is the minimum standby charge as provided for in the Act, and I would submit that any taxable benefits that could be construed in this situation should be taxed in the hands of Mrs Latta, and that they not be considered loans to Mr Latta by the company. ...

His concern was not so much whether the contracts were bona fide contracts but, assuming them to be bona fide, how much of a pay-out would be considered reasonable by the Tax Department. ... In subsequent evidence at the hearing before me I was told that the 1976 value would have been $790,000 in the case of Flanagan and $480,000 in the case of Burroughs had appropriate tax implications been considered. ... I agree with counsel for the plaintiff that it is not impossible that Flanagan might have agreed to the settlement in such an event but it simply points out, once again, to me at least, that Flanagan never considered the agreements as employment contracts but simply as negotiating devices. ...

.: — It was agreed at the outset that the two matters would be heard at the same time and the evidence would be considered in each appeal where relevant. ... At first the figure was allotted among all six shareholders but then it was considered to be an expense of the three plaintiffs only and the benefit was allotted among them. ... There was no distribution of assets that could be considered to be the deemed benefit. ...

The proper approach must be a functional one, and the scheme must be considered as a whole, taking into account the intent of the legislation, its object and spirit and what it actually accomplishes (Stubart Investments Ltd. v. ... There is much jurisprudence in Canada, the United Kingdom and the United States in which the question whether provisions in a statute are directory or imperative has been considered. ... In others, such prescriptions have been considered as merely directory, the neglect of them involving nothing more than liability to a penalty, if any were imposed, for breach of the enactment. ...

Background: [4] On June 23, 2016, the Appellant filed with the Minister a PSB rebate application seeking a GST/HST rebate of $62,620.35, for a claim period identified as January 1, 2014 to December 31, 2014. [5] Subsections 297(1) and (2) of the Act read: (1) Assessment of rebate- On receipt of an application made by a person for a rebate under section 215.1 or Division VI, the Minister shall, with all due dispatch, consider the application and assess the amount of the rebate, if any, payable to the person. (2) Reassessment- The Minister may reassess or make an additional assessment of the amount of a rebate, notwithstanding any previous assessment of the amount of the rebate. [6] As required by subsection 297(1), the Minister considered this (Division IV) PSB rebate application of June 23, 2016. ... Bains’ notices of confirmation stated also that the two January 11, 2019 PSB rebate applications were “late filed” and so could not be considered, “regardless of the circumstances”. [27] In its Notice of Appeal to this Court, the Appellant pleads that its two January 11, 2019 PSB rebate applications were amendments of its June 23, 2016 rebate application; and as well that its January 17, 2019 PSB rebate application amended the claim period erroneously expressed as commencing June 1, 2014. [28] In argument, Appellant’s counsel referenced a brief CRA document dated September 11, 2014 and entitled “Adjust a Return or Rebate”. ... Analysis: [35] The question is whether the June 23, 2016 PSB rebate application for a rebate of $60,620.35, which application the Minister on July 20, 2016 considered and then assessed the appropriate rebate as nil, and which assessment was not objected to, can on January 11, 2019 be amended and then re-considered? ...

It is not for the reviewing court to weigh and reassess the evidence considered by the decision maker (Vavilov at para 125). [40] A reasonable decision is one that is made on the basis of a coherent and rational chain of analysis, and that is justified in light of the facts and law that constrain the decision maker. ... In rendering her decision, the officer considered the applicant’s arguments. ... The applicant did not indicate what other submissions he was allegedly prevented from making. [68] The Notes and the review report mention that the officer considered the applicant’s statements with the information noted in her review report. ...