Wilson and Wilson Ltd. v. MNR, 60 DTC 1018, [1960] CTC 1 (Ex Ct) -- summary under Paragraph 12(1)(b)

By services, 28 November, 2015

Cameron, J. held that the full amounts covered by interim progress certificates of the supervising engineer became "receivable" for the purposes of the application of s. 85B(1)(b) to long-term sewer installation contracts having a fixed price per lineal foot of work done, notwithstanding that 10% of the amounts covered by the interim certificates were required to be held back until the time that the project was certified to have been completed. "Parliament has extended somewhat the ordinary concept of 'income' in relation to a business in which property is sold or services rendered and ... every amount to be received in respect of property sold or services rendered in the course of the business in the year shall be included notwithstanding that the amount is not to be received until a subsequent year ..."

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