In refusing to apply s. 67 to interest that was found to be reasonable in amount for purposes of the reasonableness limitation expressed in s. 20(1)(c), McLachlin J. stated (at p. 5678):
"... it seems to me that Parliament intended s. 67 to apply primarily to those deductions claimed under the provisions of the Act that do not have their own internal limiting clauses ... . Where the applicable provision has its own internal reference to 'reasonableness', as does s. 20(1)(c)(i), s. 67 could not apply without distorting the plain meaning of the more specific provision."