Locke, J. (concurred in by Taschereau and Fauteux, JJ.) :— These appeals were taken by Army and Navy Department Stores (Western) Limited, a company incorporated under the Companies Act of British Columbia, and Army and Navy Department Stores Limited,

Bonner T . C.J.:

ABBOTT, J.:—This is an appeal by the Minister of National Revenue from a judgment of the Exchequer Court confirming a decision of the Income Tax Appeal Board which had allowed respondent’s appeal against its income tax assessment for 1955.

Jupson, J.:—The appellant, a corporation incorporated by special Act of the Parliament of Canada, owns and operates a crude oil pipe line running from Redwater, Alberta, to a point on the international boundary south of Winnipeg, and from a point on the