Frankel Corporation Ltd. v. Minister of National Revenue, 59 DTC 1161, [1959] CTC 244, [1959] S.C.R. 713 -- summary under Paragraph 111(5)(a)

An operation of recovering non-ferrous metals from scrap material, alloying them with other non-ferrous metals to specifications required by purchasers, and selling the products, was found to be a separate business (for purposes of the Doughty doctrine) from an operation of dealing in ferrous and non-ferrous scrap, a wrecking and salvaging operation and a steel fabrication and erection operation, in light of evidence that the areas and equipment of the respective operations were separate (albeit contiguous) and the maintenance of separate accounts. Compared to the ferrous operations, the sources of material and the customers were, in general, different, and the staffs were separate. In addition, those in the trade generally regarded the smelting and alloying of non-ferrous metals as separate from that of iron and steel.