The Queen v. Consumers' Gas Co. Ltd., 87 DTC 5008, [1987] 1 CTC 79 (FCA) -- summary under Subsection 181(3)

With respect to an argument of counsel that the accounting method used by the taxpayer in offsetting reimbursements received by it against the carrying value of the related depreciable assets meant that such reimbursements were receipts that were "reflected" in its income statement, Hugessen J. stated (at p. 5010) that "the word 'reflected' is carefully chosen: the receipts themselves do not appear as income but, by reducing net cost, they go to reduce depreciation thereby increasing income."