Farmers Mutual Petroleums Limited v. Minister of National Revenue, 67 DTC 5277, [1967] CTC 396, [1968] S.C.R. 59 -- summary under Paragraph (c)

An agreement between the taxpayer and its parent corporation was characterized as an agreement to pay for a contractual right to acquire an interest in lands on which exploration and drilling had taken place by paying expenses already incurred by the parent in connection therewith, rather than as an agreement under which the taxpayer itself incurred exploration or drilling costs in respect of lands in which it had an interest. Accordingly, the amounts paid by the taxpayer to its parent did not qualify as "drilling and exploration expenses ... incurred by it on or in respect of exploring or drilling for petroleum or natural gas in Canada" for purposes of s. 83A(3) of the pre-1972 Act.