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Hollander & Sons Ltd. v. His Majesty the King, [1928-34] CTC 297, [1920-1940] DTC 275 MACLEAN P. ... The respondents, aS we have already observed, are not within s. 87 but, if they are a ‘producer’ or " manufacturer ‘ they are within s. 86.” ... If “transactions” means that the contract for the labour involved in dressing and dyeing the furs of customers was taxable as a sale against the dresser and dyer that would give to " " sale ” a meaning utterly foreign to the whole spirit of the Act; including even sec. 87(a), (b) and (d). ...

Joseph $. Irwin v. Minister of National Revenue, [1962] CTC 572 Noel, J. ... Ch. 748, to the effect that the word ‘ from ’ ’ may mean either inclusive or exclusive accord- ing to the context and subject matter and Canadian Fina Oil Limited v. ... Justice Day stated: “... as regards time, the word ‘from’ is akin to ‘after’ and excludes the day fixed for commencement of the computation. ’ ’ In Brown v. ...

Army & Navy Department Store Limited v. Minister of National Revenue, [1952] CTC 273, 52 DTC 1169, [1952] DTC 1168 ARCHIBALD, J. ... This statement is as follows: ‘ ‘ There are three companies involved in these proceedings, namely, Army & Navy Department Store (Western) Limited (hereinafter referred to as the ‘Western company’); Army & Navy Department Store Limited (hereinafter referred to as the ‘Alberta company’) and Army & Navy Department Store Limited (hereinafter referred to as the ‘Saskatchewan company’). ... Cohen) (2) The Alberta company—the shareholders are— 50 % to H. R. Cohen 10% to S. ...

& Co. Ltd. v. Minister of National Revenue, [1957] CTC 190 THURLOW, J. ... ‘ ‘ The way in which the Lord Justice Clerk applied the test is also of interest. ... " Unies you can get something worthwhile on the Drury Inlet timber, either on a lump sum or with a worthwhile deposit held so that it cannot be manipulated like the McNaughton one, we will let this timber stand hoping that prices will pick up in a reasonable period. ‘ ‘ Yours truly, • • GILLIES BROS. ...

The Shorter Oxford English Dictionary gives the following meanings for the word ‘ agency ’ ’: “1. ... Established or stable conditions —1777; organization, footing — 1799. 3. ... That which is established; a settled constitution or government — 1793. 2. ...

The Delta Glucose case was interpreting the words ‘ ‘ consumable materials ’ as they appeared in Schedule III to the Act at that time, but the words used in Schedule III in the period under consideration in the present case are ‘‘consumed or expended’’ which I consider to be broad enough to include the matrices which are discarded after one use. ... The fact that the matrices are subsequently ‘‘ ‘ consui^d or expended in the process of manufacture” of the rubber stamps as I have found does not alter the fact that before they are so consumed or expended they constitute ‘‘articles’’ rather than ‘‘materials’’. ... Armstrong & Co. Ltd. v. Deputy Minister of National Reve nue for Customs and Excise, [1967] 1 EX.C.R. 346; [1966] C.T.C. 778. 3 +R.S.C. 1927, c. 179. 4 * Judgment October 7, 1969. (1969), 23 D.T.C. 5372; [1969] C.T.C. 574. 5 *Canadian Sales Tax Reports 8561. 6 *Tariff Board Reports 1963-1966, p. 192. 7 ^Tariff Board Reports 1937-1956, p. 7. 8 tTariff Board Reports 1957-1962, p. 215. ...

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081 CAMERON, J. ... Secondly, a transaction which, on its true construction, is of a kind that would escape tax is not taxable on the ground that the same result could be brought about.by a transaction in another form which would attract tax. ’ ’ The question for determination, therefore, is ‘‘ What is the real character of the receipt?’’ ... C.I.R., 12 T.C. 1955, and similar cases. ’ ’ In the instant case, the appellant company retained the full ownership of its only capital asset—the Barclay Hotel. ...

Eplett & Sons, Limited v. Minister of National Revenue, [1954] CTC 356, 54 DTC 1189 THORSON, P. ... Gray Member. ” On March 15, 1945, Mr. Elliott wrote to the appellant as follows: ‘ ‘ Sir: Re Excess Profits Tax Act, 1940 Standard Profits Claim. ... Elliott’ Deputy Minister (Taxation) ”’ The appellant’s claim was made under Section 5 of the Act without specific reference to any subsection of it. ...

Furness Withy & Co. Ltd. v. MNR, 66 DTC 5358, [1966] CTC 482 (Ex Ct), aff'd 68 DTC 5033, [1968] CTC 35, [1968] S.C.R. 221 THURLOW, J. ... C.R. 234 at 241; [1961] C.T.C. 45 at 53. 9 + Vide Lord Macmillan in Stag Line Ltd. v. Foscolo, Mango & Co., [1982] A.C. 328 at 350. 10 [1963] S.C.R. 131; [1963] C.T.C. 51. 11 * The problem is described as follows in a note by Arnold D. ...

& R. Weir, Limited v. Minister of National Revenue, [1964] CTC 529 DUMOULIN, J. ... " The witness admits these particular operations were not transacted on the open market but through private contracts. ... So far, so good, but, then, whose bonds attracted that ‘ ‘ natural increment”? ...