Can a business be considered a profit for purposes of reducing the amount of income tax that would otherwise be payable?

The appellant also relies on more recent jurisprudence that stands for the proposition that, for income tax purposes, an advantage that flows exclusively from the provisions of the tax statute is not a profit, and a business cannot consist of a transaction whose sole purpose is to reduce the tax that would otherwise be payable: Moloney v. Canada, [1992] F.C.J. No. 95, [1992] 2 C.T.C. 227, 92 D.T.C. 6570 (F.C.A.); Loewen v. Canada, 1994 CanLII 3478 (FCA), [1994] 2 C.T.C. 75, 94 D.T.C. 6265 (F.C.A.). I am unable to draw any analogy between those cases and this one. The appellant was not engaging in tax avoidance transactions, nor was it attempting to derive a profit from tax deductions or tax credits in the Income Tax Act. It simply adopted a practice of overpaying its instalments in order to comply with its income tax obligations at the least possible cost.