TDS Group Limited v. The Queen, 2005 DTC 786, 2005 TCC 40 -- summary under Canadian Manufacturing and Processing Profits

The taxpayer, which sprayed automobile and truck parts with a corrosion inhibitor and specially packed them in kits before shipping the kits to plants in third-world countries for assembly there as automobiles, was found to be engaged in the processing of goods for sale. Without the taxpayer's input in assembling the kits, the offshore manufacturers could not have produced a vehicle, and it was not relevant that the taxpayer did not own the parts (the car manufacturers did).