Great Atlantic and Pacific Tea Co. Ltd. v. The Queen, 79 DTC 5401, [1979] CTC 509, [1980] 1 SCR 670 -- summary under Cumulative Taxable Income

The argument of the taxpayer that s. 133(9)(b)(ii) did not require that the taxation year have been completed in order for taxable income earned prior to the particular time to be included in its cumulative taxable income was rejected in light of the reference in the preamble of ss.133(9)(a) and (b) to "at any particular time" and in light of "the practical requirement that the ascertainment of the various quantities going into the computations in these subparagraphs must be possible at the moment in question."