Canada (National Revenue) v. Kitsch, 2003 DTC 5540, 2003 FCA 307 -- summary under Redundancy/reading in words

By services, 28 November, 2015

S.231.2(1)(a) of the Act, which referred to a right of the Minister to require the production of "any information", was found not to be restricted to the production of documents and records given that documents and records were specifically dealt with in s. 231.2(1)(b) of the Act. After referring to the statement in Communities Economic Development Fund v. Canadian Pickles Corp. [1991] 3 SCR 388 that "it is a principle of statutory interpretation that every word of a statute must be given meaning", Malone J.A. stated (at p. 5543):

"Applied in this case, that principle dictates that meaning must be given to both paragraphs (a) and (b) of subsection 231.2(1), and unless there is good reason to the contrary, a different interpretation must be given to both paragraphs and different meanings to the words 'information' and 'document'."

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