Marceau
J.A.:
-
In
our
view,
this
appeal
must
not
succeed.
Both
in
this
Court
and
at
trial,
the
entire
dispute
revolved
around
the
interpretation
to
be
given
to
the
words
“manufactured
or
processed”
in
subparagraph
(i)
of
paragraph
125.1
(3)(1)
of
the
Income
Tax
Act
as
it
read
when
the
Minister
made
the
assessments
here
in
issue
and
as
it
still
reads.
Like
the
trial
judge,
we
do
not
feel
that
these
past
participles
of
the
verbs
“to
manufacture”
and
“to
process”
can
be
given
a
content
or
meaning
the
scope
of
which
would
conflict
with
“manufacturing”
and
“processing”,
the
gerund
forms
of
the
same
verbs
in
conjunction
with
which
they
are
to
be
read.
Our
conclusion
is
not
really
based
on
the
directives
in
the
Interpretation
Act,
including
section
15
thereof,
since
this
is
clearly
not
an
interpretation
provision
in
the
strict
sense;
our
conclusion
is
based
primarily
on
our
understanding
of
what
the
enactment
is
intended
to
express
and
also
on
the
logic
of
the
language.
The
appeal
will
therefore
be
dismissed
with
costs.
Appeal
dismissed.
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