DENNISTOUN, J.A. (dissenting) :—This is an appeal from a judgment of Major, J., in the Court of King’s Bench [1943] 3 W.W.R. 305. The City of Winnipeg is the appellant. A ease has been stated by the Board of Revision on the application

THORSON, J :—The issue in this appeal is whether a Dominion Government subsidy paid under the authority of the Dry Docks Subsidies Act, 1910, as amended, constitutes taxable income to the appellant under the Income War Tax Act.

MACF'ARLANE, J.—This is a Motion for a Writ of Certiorari to remove into this Court the decision of the Board of Referees, appointed by the Minister of National Revenue, pursuant to the provisions of the Excess Profits Tax Act, 1940, being Chapter 32

THORSON, J.:—The appellant acted as agent or correspondent for certain underwriting members of Lloyd’s of London, England, in the writing of Workmen’s Compensation, Employer’s Liability and Occupational Disease insurance, under an annual memorandum of authorization by which the

Rand J. (Concurred in by Taschereau, J.) :—This is an appeal from the Exchequer Court [[1943] C.T.C. 281] which upheld a ruling by the Minister of National Revenue that a payment of $1,500. received by the appellant during the year 1940 was not

The Court, having heard the parties and deliberated; Seeing :

The trustee prays for direction as to the nature of the claim of the Department of National Revenue.

HUDSON J. (Concurred in by RINFRET, DAVIS and TASCHEREAU. JJ.)

ROBERTSON C.J.0.:—This is an assessment appeal by : way of stated case under s. 85 of the Assessment Act, R.S.O. 1937, c. 272, from the decision of Judge Macdonell, of the County Court of the County of York.

MARTIN C.J.S.:—These are appeals by way of stated case from the decisions of the Saskatchewan Assessment Commission in which it was held that the appellant companies are liable to assessment in respect of business carried on by them on Crown property. For

Bond C.J.S.C.:—For the sake of precision I set forth at length the joint factum or case as submitted: