The
Chief
Justice:—In
the
opinion
of
the
Court
the
majority
of
the
Tariff
Board
applied
an
unduly
narrow
interpretation
of
the
word
“development”
in
subparagraph
6(b)(i)
of
Part
XVII
of
Schedule
III
of
the
Excise
Tax
Act
and
compounded
the
error
by
confining
the
meaning
to
“initial”
development,
thus
adding
a
limiting
expression
not
found
in
the
statute.
For
the
reasons
given
by
the
learned
dissenting
member,
Mr
Gorman,
the
appeal
will
be
allowed
and
it
will
be
declared
that
the
importation
of
the
helicopter
in
question
is
exempt
under
subsection
29(1)
of
the
Act
from
consumption
or
sales
tax.
Appeal
allowed.
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