In accepting the taxpayer's submission that royalties (calculated as apercentage of sales proceeds) received by it from the licensee of its interest in an iron ore body qualified as "income derived from the operation of the mine" for purposes of an exemption for such income generated in the first 36 months following commencement of production, Abbott J stated (at p. 1033) that he accepted:
…that the ordinary meaning of the words "derived from the operation of a mine" is broader than that contended for by appellant, that the word "derived" in this context is broader than "received" and is equivalent to "arising or accruing" (vide Commissioner of Taxation v. Kirk, [1900] A.C. 588 at 592) and that the expression is not limited to income arising or accruing from the operation of a mine by a particular taxpayer.