The appellant appealed a reassessment that disallowed its deduction of $63,134 claimed as scientific research and experimental development (SR&ED) expenditures and an investment tax credit of $23,822 for the 2015 taxation year.
The projects involved the development of portable modular concrete panels and the improvement of a process for mixing and pouring concrete.
The Tax Court of Canada dismissed the appeal, finding that the activities did not meet the five criteria for SR&ED established in Northwest Hydraulic Consultants Ltd. v. The Queen.
The court concluded that there was no scientific or technical uncertainty, no systematic testing of hypotheses, no scientific method adopted, no scientific or technological advancement, and no detailed record kept.
