The appellant was denied input tax credits, in part, based on the supply by it of staterooms to passengers travelling on ferries (for which it made separate charges but did not charge GST) was part of the single supply of the ferry service. In allowing finding that there was a separate supply of the rental of the staterooms, Campbell J stated (at para. 65):
Common sense dictates that the provision of ferrying services remains a useful and valuable supply minus the rental of staterooms. Staterooms are not an essential component to the overall supply of transportation services. In fact, there are insufficient numbers of staterooms to accommodate every passenger, even if all of the passengers on any route wished to purchase a stateroom.