In finding that the appellant, which was incorporated as a non-profit company, but which “was carrying on a business concern much the same as any other travel agency” and from which “it made quite considerable profits” did not qualify under s. 149(1)(l), Couture DJ first quoted the statement in British Launderers Research Association v. Central Middlesex Assessment Committee and Hendon Rating Authority, [1949] 1 All E.R. 21 that:
The word “exclusively” must be given its full effect. It is not sufficient that the society should be instituted "mainly" or “primarily” or “chiefly” for the purposes of science, literature, or the fine arts, it must be instituted "exclusively" for those purposes.
After noting that the appellant made some donations, he concluded:
As in the Woodward's case, the appellant's philanthropic purpose or object could not have been achieved unless it had carried on its business which was a commercial operation for profit.