Qit-Fer et Titane Inc. v. The Queen, 92 DTC 6071, [1992] 1 CTC 39 (FCTD), aff'd on different grounds 96 DTC 6213 (FCA) -- summary under Manufacturing or Processing (l)

Rouleau J. applied s. 15(1) of the Interpretation Act in finding that because ss.125.1(3)(b)(v), (vi) and (vi.1) excluded the production of ferric oxide and titanium dioxide from "manufacturing or processing" the sale of such production also was excluded from "the selling ... of goods manufactured or processed in Canada" referred to in s. 125.1(3)(b)(x) of the Income Tax Act. Accordingly, because the taxpayer's sales of ferric oxide and titanium dioxide could not be included in its sales of goods manufactured or processed in Canada for purposes of s. 125.1(3)(b)(x), its secondary activity of manufacturing iron powder did not qualify.