Bowden v. Canada, [2011] GSTC 109, 2011 FCA 218 -- summary under Commercial Activity

The appellant had claimed input tax credits (ITCs) in respect of alleged businesses conducted from his home for which he had only minimal revenues ($300 in sales over a three year period.) Before allowing a portion of the appellant's ITC claims on procedural grounds, Sharlow JA rejected the appellant's submission that a business which has no personal or hobby element is not required (on the authority of Stewart) to have a reasonable expectation of profit (REOP) in order to qualify as a commercial activity, after noting (at para. 8) that the definition of commercial activity specifically requires that an individual have a REOP.