Thurlow,
C
J:—We
are
all
of
the
opinion
that
the
Tariff
Board
did
not
err
in
law
in
holding
that
the
respondent’s
publications,
“Auto
Trader”
and
“Truck,
Bike
and
Boat
Trader”
are
exempt
from
the
sales
tax
imposed
by
subsection
27(1)
of
the
Excise
Tax
Act
by
virtue
of
subsection
29(1)
and
Schedule
III,
Part
Ill,
subparagraphs
3(b)(iv)
and
(v)
of
the
Act.
To
restrict
the
meaning
of
“space
therein”
and
“space
per
issue”
in
those
provisions
to
that
portion
of
the
total
space
of
the
publication
that
is
occu-
pied
by
printed
matter,
for
the
purpose
of
calculating
the
percentage
of
space
devoted
to
advertising,
referred
to
in
the
exempting
provisions
would,
in
our
opinion,
involve
adding
wording
such
as
“on
which
matter
is
printed”,
which
is
not
in
the
statute.
We
think
that
to
do
this
would
be
to
amend
the
provisions
rather
than
to
interpret
the
expressions
used.
This
is
particularly
so
in
the
case
of
the
expression
“space
therein”
which
refers
to
the
space
in
the
newspaper
itself.
The
appeal
accordingly
fails
and
is
dismissed.
Appeal
dismissed.
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