Soneil International Limited v. The Queen, 2011 DTC 1282 [at at 1592], 2011 TCC 391 -- summary under Scientific Research & Experimental Development

D'Arcy J. denied the taxpayer's claimed SR&ED credits arising from the development of various electrical systems for use in wheelchairs - a power optimizer to switch power between the front and back wheels of a wheelchair or scooter, an inhibitor to ensure that a wheelchair remain stationary while being charged, a virtual battery system to derive 36 volts of potential from two 12-volt batteries, and a multi-voltage output charger. The purported technological uncertainty was not compelling, as the issues raised were design problems rather than scientific problems. (For example, the purported uncertainty in the virtual battery project was "whether a safe and effective virtual battery could be developed that would be suitable for use by disabled people operating wheelchairs.") The work could be completed using existing electronic and mechanical components, and products performing similar functions already existed.