Précis: The Tax Court struck a portion of the Crown’s reply in this case on the basis that it was dealt with transfer pricing while at the same time the Crown argued that there had been no transfer from the non-resident concerned. The Federal Court of Appeal allowed the Crown’s cross-appeal on this point only. The Crown’s cross-appeal on two other points was dismissed. The taxpayer’s appeal arguing that more provisions should have been struck was also dismissed.
AgraCity Ltd. v. R. - FCA: Crown can have inconsistent pleadings in related appealsREAD MORE »