solely

Improvements were made to the portion of the building where the manufacturing operations of the plant will be carried out in order to comply with government standards of the applicable Health Products and Food Branch. In addressing whether such improvements could qualify under Class 8(b) (so that they could then qualify under Class 43), CCRA indicated that the word “solely” had a more restrictive meaning than that of a dominant purpose, and then stated:

The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. It took the position that the costs of the property added to the Shells for this work should be included in Class 29 rather than Class 13.