The Quebec manufacturing and processing credits claimed by the taxpayer in connection with equipment acquired for use by it in its greenhouse cucumber-growing operation turned on whether such equipment was Class 29 property. A Quebec regulation (similar to the exclusion in (a) of the ITA definition in s. 125.1(3) of “manufacturing or processing”) excluded “farming” from “manufacturing or processing.” In finding that the greenhouse operation was farming, so that the exclusion applied, Vaillant JCQ stated (at paras. 34-35, TaxInterpretations translation):
Greenhouse cucumber growing at Serres Toundra requires the same elements as those needed for cultivation in home gardens or farmers' fields: soil, water, light, heat and fertilizers.
It is true that, thanks to technological advances, the soil in which cucumber plants are grown is made up of a food-grade mineral fibre substrate instead of soil. However, this substrate is only a substitute. It plays the same role as soil, i.e., it hosts the roots of the plant which, clinging to the substrate, receive the water and nutrients necessary for the growth of the plant and its fruit.
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