The appellant appealed the Minister's assessment disallowing its claim for scientific research and experimental development (SR&ED) expenditures and investment tax credits related to the development of a software project.
The Tax Court of Canada applied the five criteria from Northwest Hydraulic to determine if the activities constituted SR&ED.
While the court found there were technological uncertainties and hypotheses formulated, it concluded the appellant failed to show that a systematic investigation was carried out in accordance with the scientific method or that detailed records were kept.
The appeal was dismissed.
