Coopers & Lybrand Ltd., Trustee of Hawboldt Hydraulics (Canada) Inc. v. The Queen, 92 DTC 6452, [1992] 2 CTC 363 (FCTD) -- summary under Class 8

By services, 28 November, 2015

An operation of fabricating cylinders, pistons, rods or other parts to be incorporated into hydraulic components which customers of the taxpayer had delivered to it for repair constituted a manufacturing or processing operation, with the result that the equipment used to fabricate the parts were Class 29 rather than Class 8 assets. The Crown Tire case was distinguished on the ground that in that case no product was produced by the taxpayer before the work and materials provided became the customer's property by adhesion of the materials.

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