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Appeal allowed; four of six air quality monitoring projects qualified as SR&ED experimental development.
The appellant appealed the Minister's disallowance of its claims for scientific research and experimental development (SR&ED) investment tax credits for the 2014 and 2015 taxation years.
The Minister had disallowed the claims on the basis that the air quality monitoring work did not constitute SR&ED.
The Tax Court of Canada found that the appellant had satisfied its evidentiary burden for four of the six projects, demonstrating that the work was undertaken to resolve technical uncertainties for the purpose of achieving technological advancement.
The appeal was allowed and the matter referred back to the Minister for reconsideration and reassessment.