Canada v. Bowker, 2023 FCA 133 -- summary under Noscitur a Sociis

Pelletier JA first found that in light of the noscitur a sociis principle and the “the specific context of paragraph 162(7)(a) dealing with the failure to file information returns,” and in the context of posing the question ”why a penalty of very broad application (assuming the interpretation [incorrectly] proposed by the respondent) would be tucked away in a paragraph within a subsection dealing with a specific failure to file certain documents” (para. 48) so that “the general language of paragraph 162(7)(b) would be limited to instances of failure to file returns or to provide information not specifically enumerated in the balance of section 162” (para. 49).