The appellant non-profit corporation operated a large low-rental residence for indigent elderly persons and sought a full municipal real estate tax exemption as a reception centre.
The Court held that tax legislation is interpreted under the ordinary rules of interpretation, with the applicable degree of strictness or liberality determined by legislative purpose, substance prevailing over form where consistent with statutory text and purpose, and only residual unresolved doubt favouring the taxpayer.
Applying that approach, the Court concluded the entire facility qualified as a reception centre under the health services legislation and was used for the statutory purposes contemplated by the municipal taxation statute.
The exemption was not conditional on holding a permit for the whole facility, and the specialized tribunal's decision restoring full exemption was reinstated.
