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Here there was a ‘‘ Dealer Participation Agreement’’ entered into between Thornerest and Ford so that Thornerest took part in the sales incentive program. ... Because of the conclusion I have reached on the first issue in this appeal, that is, that the amount of $1,384 is properly included in the appellant’s income by virtue of Section 5(1) (a) of the Income Tax Act, it is not necessary for me to consider the alternative submission on behalf of the Minister that the sum of $1,384 should be included in the appellant’s income as a benefit or advantage conferred upon him as a shareholder of Thorncrest within the meaning of Section 8(1) (¢). ...

.’’, ‘‘a six inches drainage pipe below the basement floor level...” plus the requisite surface connection points; and, also, to erect‘ ‘ washroom and toilet facilities in the basement and ground floor level for a total personnel of seventy- five (75) persons together with further facilities on the second floor for a personnel of forty (40) persons, in accordance with the City of Montreal Health Department authorities and the plan hereto annexed’’. ... The appellant’s learned counsel argued that these oft described installations did not constitute an enduring benefit, ‘ they were made’’, contended Mr. ...

:—These are appeals from assessments by the Minister under the Income Tax Act, R.S.C. 1952, ¢. 148, wherein additional tax was levied against the appellant in respect of its 1961 to 1964 taxation years inclusive. ... The amounts of the municipal property taxes assessed and so paid in respect of the demised premises were: for the year 1961 $ 4,217,97 for the year 1962 7,739.65 for the year 1963 10,878.88 for the year 1964 28,743.01 Total $51,579.51 Melforte Limited deducted and remitted to the Minister withholding tax under Section 106(1) (d) of the Income Tax Act at the rate of 15% on the rent of $60,000 per year and $150,000 per year, when applicable, as stipulated under the leases between it and the appellant. ...

Evans & Sons was a member of the unincorporated Board as an active associate member. ... Evans & Sons, left that firm and formed a joint stock company under the name of Carruthers, Evans and Christie Limited to carry on a real estate brokerage business. ...

., continues: “•.. It was argued that the fact that the finance company would return a contract, when requested and repaid, indicates that the appellant had a right to redeem the contracts, but in my view, this fact is consistent with other explanations as to why the finance company would return a contract, and in the absence of evidence of a term of the arrangement giving the appellant a right of redemption, I do not regard it as indicative of such a right.” ... Hill dixit) ”. How then can the appellant, fully paid, and who, understandably so, did not take the trouble of entering in its ledgers ‘‘the amounts receivable from any particular customer’’, lay any claim to the provisions of Section 75B(l)(d). ...

Reference may be made to the following cases: Deputy Minister of National Revenue for Customs & Excise v. ... Indeed, the respondent’s representative before the Board referred to them at various times as ‘‘containers’’, ‘ 'bread shipping carriers”, ‘‘delivery containers’’, ‘‘wire shipping containers’’, "wire delivery trays”, and ‘‘bread shipping containers’’. ...

The provisions of Section 40A pertinent to the present appeal read as follows: “40A. (1) There may be deducted from the tax otherwise payable for a taxation year by a manufacturing and processing corporation an amount determined by the following rules: ’ (The detailed rules for determining the amount of the deduction are then set out but are not reproduced here since they are not material to a consideration of the present appeal.) “(2) In this section, (a) ‘manufacturing and processing corporation’ means a corporation that had net sales for the taxation year in respect of which the expression is being applied from the sale of goods processed or manufactured in Canada by the corporation the amount of which was at least 50% of its gross revenue for the year, but does not include a corporation whose principal business for the year was (i) operating a gas or oil well, (ii) logging, (iii) mining, (iv) shipbuilding, (v) construction, or (vi) a combination of two or more of the classes set out in subparagraphs (i) to (v) inclusive; (Paragraphs (b) to (d) are not reproduced herein.) (3) For the purpose of paragraph (a) of subsection (2) (a) goods processed or manufactured shall be deemed not to include goods that have been packaged only...’’ ... Here it is plain that Section 40A of the Income Tax Act is dealing with manufacturing and processing corporations generally and that the words, ‘‘manufacturing’’ and ‘‘ processing’’ as used in subsection (2a) of Section 40A are used in their ordinary unrestricted senses. ...

Cas. 473 at p. 478; he added that one “must find words to impose the tax, and if words are not found which impose the tax,* it is not to be imposed. ’ The same learned judge expressed a similar opinion in the case of Partington v. ... Exch. 19); " It is a well-established rule that the subject is not to be taxed without clear words for that purpose, and also that every Act of Parliament must be read according to the natural construction of its words’.’’ ...

The section is in Part IV of the Act, dealing with ‘‘Special provisions relating to the incidence of the tax’’, and immediately under the heading ‘‘ Transfers to Evade Taxation’’. ... Attorney General (1869) L.R. 4 H.L. 100 at p. 122, where Lord Cairns made the classic statement: " If the person sought to be taxed comes within the letter of the law he must be taxed, however great the hardship may appear to the judicial mind to be. ...

Goodman was a member of the law firm of Goodman, Cooper, Cohen & Farano, and the said law firm and in particular Mr. ... Guest, [1898] 1 Q.B. 759 at 764 per Lindley, M.R.: ‘... Where an attorney intrusted confidentially with a document communicates the contents of it, or suffers another to take a copy, surely the secondary evidence so obtained may be produced. ... Holmested & Langton’s Ontario Judicature Act, 5th Edition, at p. 1032: “Secondary Evidence. ...