In finding that the reduction of capital cost pursuant to s. 13(7.1) occurs in the year in respect of which the investment tax credit was utilized, rather than the subsequent year in which the return was filed claiming that credit, Hugessen J.A. stated (p. 6190):
"On their ordinary meaning the words 'has deducted' and 'deducted' in subsection 13(7.1) refer to operations effected in respect of the taxation year to which those deductions were applied, notwithstanding that the actual mathematical operations themselves may have taken place at a subsequent time."