Rouleau J. found that in Coca-Cola Ltd. v. Deputy Minister of National Revenue for Customs and Excise, 84 DTC 6081, [1984] CTC 75 (FCA), the Court refused to entertain an argument, apparently based on s. 33(3) of the Interpretation Act, that the expression "manufacture or production" should be interpreted by reference to the definition of the expression "manufacturer or producer" in s. 2 of the Excise Tax Act. Rouleau J. added (p. 6073):
"In so doing, the court also seems to infer that 'manufacture or production' were not in themselves parts of speech and grammatical forms of 'manufacturer or producer' ..."