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Such a contravention may be an ingredient to be established in a charge under that section but to do so without more falls far short of proving a charge of wilful evasion under that section. The contravention may or may not be wilful. As was pointed out by counsel for the respondent, if this submission by counsel for the appellant were to prevail, the result would be that if a taxpayer filed his tax return on May 1st in a given year and such late filing was intentional, then that taxpayer would be subject to the same basic penalty of 50% of the unpaid tax as a taxpayer who deliberately files his return one or two years late. ...

.), where two pharmacists complained to the Syndic of the Ordre des pharmaciens about charges levied by "Cumberland", a non-pharmacist, on fees or profit resulting from the sale of medicines, in contravention of the Code of Ethics of Pharmacists, which reads in relevant part:      DUTIES AND OBLIGATIONS TOWARDS THE PROFESSION              §1          Derogatory acts   4.01.01.           ... (t)       sharing his fees or the profit resulting from the sale of medicines with a person who is not a pharmacist;   [12]     The Quebec Court of Appeal made the following comments at paragraphs 16 to 20:   [TRANSLATION] ¶  16      That being said, the trial judge properly found that under the contractual structure created trial by Cumberland, the pharmacists are sharing their fees (or profit) with the franchisor in contravention of their Code of Ethics. ...

GVL et QMI invoquaient également que monsieur Chagnon avait manqué à son obligation de loyauté à titre d’administrateur et de dirigeant de GVL en contravention des articles 322 et 323 du Code civil du Québec et à son obligation précontractuelle de renseignement en contravention des articles 6, 7 et 1375 du Code civil du Québec.   ...

., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the Court may not interfere. ... If, however, those facts are, in the opinion of the Court, insufficient in law to support the conclusion arrived at by the Minister, his determination cannot stand and the Court is justified in intervening. [25] There are thus four tests which the Tax Court of Canada can apply to decide whether it is entitled to intervene: the Minister (1) did not have regard to all the circumstances of the employment; (2) considered irrelevant factors; (3) acted in contravention of a principle of law; or (4) based his decision on insufficient facts. [26] The Court went on as follows: In my view, the respondent's position is correct in law except that it does not indicate what powers the Court enjoys once an intervention is deemed to be justified. [27] After making further observations, the Court added: It is therefore appropriate, in the case at bar, to analyze the provisions of the Unemployment Insurance Act under which the jurisdiction of the Tax Court is exercised in order to determine the type of decision it may render. ...

., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors or has acted in contravention of some principle of law, the Court may not interfere. ... If, however, those facts are, in the opinion of the Court, insufficient in law to support the conclusion arrived at by the Minister, his determination cannot stand and the Court is justified in intervening. [27] There are thus four tests which the Tax Court of Canada can apply to decide whether it is entitled to intervene: the Minister (1) has not had regard to all the circumstances of the employment; (2) has considered irrelevant factors; (3) had acted in contravention of some principle of law; or (4) has based his decision on insufficient facts. [28] The Court went on as follows: In my view, the respondent’s position is correct in law except that it does not indicate what powers the Court enjoys once an intervention is deemed to be justified. ...

The appeals before the Court are from reassessments under the Income Tax Act (the Act), which the Appellants all allege were made outside the normal reassessment period, and which they say were based on documents and information obtained by the Canada Customs and Revenue Agency (CCRA) in contravention of the Appellants' rights under sections 7 and 8 of the Canadian Charter of Rights and Freedoms. ... As such, the Appellants say that the Reassessments should be vacated pursuant to subsection 24(1) of the Charter; (d)        The admission into evidence before this Court of evidence obtained by the Minister in contravention of sections 7 or 8 of the Charter would bring the administration of justice into disrepute. ...

The provisions do not state "no contract shall be entered into using a SIN relied upon in contravention of paragraphs 141(1) (a) or (b) ". ... Does this then imply that if an employee does so deceive an employer in contravention of paragraph 141(1) (b) that the ensuing contract is illegal? ...

., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere. ... Wrights' Canadian Ropes Ltd., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere ...

., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere. ... Wrights' Canadian Ropes Ltd., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere ...

., contends the respondent, unless the Minister has not had regard to all the circumstances of the employment (as required by subparagraph 3(2)(c)(ii) of the Act), has considered irrelevant factors, or has acted in contravention of some principle of law, the court may not interfere. ... If, however, those facts are, in the opinion of the court, insufficient in law to support the conclusion arrived at by the Minister, his determination cannot stand and the court is justified in intervening. [18]     There are thus four tests that the Tax Court of Canada can apply in deciding whether it is justified in intervening:           the Minister of National Revenue (1)      has not had regard to all the circumstances; (2)      has considered irrelevant factors; (3)      has acted in contravention of some principle of law; or (4)               has based his decision on insufficient facts. [19]     In Ferme Émile Richard et Fils Inc. (178 N.R. 361) dated December 1, 1994, the Federal Court of Appeal summarized Tignish Auto Parts Inc. as follows:... ...