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The Respondent asserts that the CRA considered the Applicant’s medical and financial hardship but reasonably found that they did not warrant relief. [16] I agree with the Respondent. [17] I first note that the Applicant’s new evidence will not be considered in this judicial review. In applications for judicial review, “only the information that was before the decision-maker can be considered” (PPSC Enterprises Limited v. ... In my view, the CRA “account[ed] for the evidence before it” and considered the “concerns raised by” the Applicant (Vavilov at paras 126, 127). ...

Having considered all of the above I am satisfied that you were considered for all staffing actions and that you did not meet the minimum requirements for any of the staffing actions.  ... Counsel submitted that the situation is analogous to that considered by Justice Dawson of this court in Anderson v. ... Only applicants who meet the pre-requisites will be considered for assessment, which is the second stage of the selection process ...

The jurisprudence has established that the Commission is presumed to have considered the submissions and Rogers notes that the decision letter states that the Commission did so. ... There is usually no reason to question a statement that submissions have been considered. ... Paranthaman’s submissions or whether and how the Commission considered the submissions and found the explanation not to be reasonable. ...

Packaging imported sugar in individual serving size packets is considered to be same condition. ... The plastic bottles, caps, and labels are considered to be “same condition” when exported. ... What should be considered in assessing the reasonableness of the decision? ...

There was no possibility of obtaining payment of the principal amount and no means of resolving the debt. [8]                CCRA considered in detail Mr. ... Particularly, it considered that Mr. Little had knowingly allowed an outstanding balance to exist and interest to accrue on Litmar's accounts without taking quick steps to remedy this problem. [9]                According to Mr. ... Little's plight and his obvious effort to deal with a difficult financial situation, the Court cannot accept his contention that his circumstances were not fully considered by CCRA. ...

Under the VDP Policy, a disclosure must be considered voluntary in order to be considered as a valid voluntary disclosure.  ... It is argued, however, that knowledge of enforcement activity must necessarily be considered in respect of specific taxation years.  ...   [12]       The decision-maker swears that: I specifically considered the Applicant’s submission that Mr.  ...

The decision and the issues [12]            In said letter, it is indicated that: I have carefully considered all of the information available to me including the original request to determine if the Taxpayer Relief Provisions apply. ... Also, it must be considered that when the Fairness Committee considered the Applicant’s request it had before it not only the summary of facts but also the Applicant’s letter of August 27, 2008 and the documentation pertaining to the first review. ... What is more, he is presumed to have considered all of the evidence before him (Woolaston v. ...

As there were no other alleged breaches of fairness identified I have not considered this issue ... MacIntosh’s submissions in support of relief were acknowledged, summarized and considered. ... As noted above, the Minister considered both Mr. MacIntosh’s contention that he was an innocent victim of the coordinators of the UnionCAL and Avtel programs and his actions in seeking to retire his tax debt. [26]   The Minister also considered the degree of care exercised by Mr. ...

However, it seems clear to me that if A purchases goods from B, the cost of transporting the goods from B's premises to A's premises may or may not be considered as a part of the price. ... It would be exceptional indeed for the cost of transportation from the original vendor to B not to be considered as an integral part of B's general cost for the goods for the purpose of determining his resale price and such expenditures would normally form an integral part of such price. ... When considered in this context, Regulation 28(1) makes sense and does not conflict in any way with either subparagraph (i) or (ii) of paragraph 30(1)(c), that is, when “transportation prepaid by the suppliers” in the regulation is taken to mean the transportation which has been prepaid by the Canadian supplier who has imported the goods and sold them to a licensed wholesaler. ...

He also noted that while employment income is considered eligible, so too is income received as maternity benefits and EI. ... Pension funds may not reasonably be considered in the eligibility assessment. [26] I also accept as reasonable the fact finding by CRA that the Applicant made less than $5,000 in the 12 months prior to his application. ... This is clear in the second review letter sent to the Applicant, which notes that the income being considered is that “before taxes”. ...