Bowman A.C.J. found (at p. 2015) that although refund interest was not referable to property held in the course of carrying on a business in Canada for purposes of s. 138(9), it nonetheless was:
"income from a business carried on in Canada. Its genesis is the income earned from the appellant's business in Canada upon which the appellant has an obligation to pay tax and in respect of which it must make instalment payments. It is not from casual investments made independently of its business. The reason for instalment payments is that the appellant has a business here which requires it to make such payments even though for business reasons the appellant decided to make larger instalment payments than were necessary."