Woods J. found that the taxpayer could include interest from its tax refund in the calculation of its gross resource profits, given that the interest was sufficiently connected with the taxpayer's coal business. She stated at para. 21:
[T]he appellant's right to refund interest arose in the course of managing its tax obligations. These obligations, in turn, arose as a consequence of earning profits from the production and processing of coal. There is no other significant source of income on which the tax is payable.
And at para. 27:
It is also useful to look at the nature of the issues in the tax dispute that led to the refund, namely, the issues on which the appellant was successful. If the factual circumstances that gave rise to these issues is integral to production and processing activities, sufficient integration has been established in my view.