Before going on to find that the taxpayer's claim for investment tax credits did not satisfy the clear requirements of what then was s.127(9)(a), Linden J.A. stated (at p. 5327):
"The use of the Budget paper was not helpful in this case, because the words used in it were more general than those employed in the legislation itself. There is no ambiguity in the meaning of the words used in the Act so as to invite reliance on the Budget paper."