IncoLimited v. The Queen, 2004 TCC 373, aff'd 2005 DTC 5110, 2005 FCA 44 -- summary under Drafting Style

By services, 28 November, 2015

Sarchuk J. stated (at p. 2852) before going on to find that the interpretation by the taxpayer of s. 152(1.2) was contrary to the plain meaning of that provision when read in context:

"It has also been observed that the plain meaning approach of itself is not a total rejection of purposive interpretation but is simply a recognition that object and purpose can play only a limited role in the interpretation of a statute that is as precise and detailed as the Act."

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