Does the definition of the word “transaction” include an arrangement?

Counsel for the Respondent relied on the decision of Justice Thurlow in Minister of National Revenue v. Granite Bay Timber Co.[2] to state that the word “transaction” was wide enough to include an arrangement. In conclusion on this issue, counsel stated that by virtue of subsection 247(11) of the Act, the definition of the word “transaction” in section 247 applies to that word as it is used in subparagraph 152(4)(b)(iii).