Hogan J. found that the registrant, a convenience store operator, was entitled to input tax credits for its purchase of automated banking machines, which were used by it in its stores to provide exempt financial services (i.e., cash withdrawal services to its customers). Hogan J noted (at para. 52) that a "registrant can claim ITCs in respect of financial services contemplated by subsection 185(1) because the legislator chose to deem inputs for the purpose of financial service transactions to be inputs for the purpose of commercial activities” and further indicated that the words "relate to" indicate that the exception in s. 185(1) has a wide scope (only "some connection" is required: para. 50), rather than being restricted to financial services which are "incidental or ancillary to a registrant's primary business operations," as contended (at para. 46) by the Minister. Hogan J. stated (at para. 53):
The appellant placed ABMs in its stores to maximize customer visits. ... The evidence shows that ABM users often made impulse purchases following a withdrawal of money from their bank accounts. The appellant profited from both transactions. In my opinion, this is a sufficient link or connection to justify a finding that the appellant's ABM operations "relate to" its other convenience store activities.