Mandeep Kandola

The appellants appealed GST/HST reassessments related to the self-supply of a newly constructed residence.

The Minister determined they were builders who made a taxable self-supply and did not qualify for the personal use exemption.

The Tax Court found that the appellants' pattern of buying, building, and selling properties constituted an adventure in the nature of trade, making them builders.

The Court also found the primary purpose of the property was inventory, not residency, precluding the personal use exemption.

The fair market value was determined to be $915,000 based on the respondent's expert appraisal.

The appeals were dismissed.