The Respondent brought motions for leave to amend the replies in two appeals.
The Appellant did not oppose the motion in the second appeal.
In the first appeal, the Respondent sought to add arguments relating to a tax shelter, window dressing, and the GAAR.
The Court denied leave to add the tax shelter and window dressing arguments because the Respondent had previously represented to the Court that it would not rely on the tax shelter argument, had missed previous opportunities to plead these arguments, and the proposed amendments were not timely.
The Court granted leave to add the GAAR arguments and other minor revisions.
