Kruco Inc. v. The Queen, 2001 DTC 668 (TCC), aff'd 2003 FCA 284 -- summary under Interpretation Bulletins, etc.

Dussault T.C.J. indicated (at p. 690) that accepting the administrative policy of the Minister in that case respecting the computation of safe income (a policy that was not clearly based on the terms used by Parliament) would be tantamount to an inappropriate attribution of a legislative character to departmental directives, and would have the effect of inappropriately treating the Minister as having the power to apply an administrative policy as though it were an independent source of law.