manufacture

The taxpayer purchased in bulk lots, by the pound, old and worn-out motor vehicle tires and put them through a process of repair, treatment (including being pressed and partially cooked in a boiler) and retreading, and sold the retreaded tires. Throughout the process the sidewall of the tire was not dismantled or destroyed, the numerical identification of the original tire was not destroyed, the name of the manufacturer of the original tire was still clearly marked upon its sidewalls.

The respondent imported “greyish, non-descript” slabs of raw marble (sometimes as long as 16 feet) and, after finishing them, installed them in buildings as subcontractor. The finishing work included matching slabs so that the veining would match, grouting voids, rodding weakened slabs, gluing broken slabs, grinding, rough and fine polishing, cutting and finishing the edges. In finding that the finished slabs were “goods produced or manufactured in Canada” within the meaning of s. 30(1)(a) of the Excise Tax Act, R.S.C. 1952, Spence J stated (at p.

The taxpayer was a bank which also was the landlord of the Royal Bank Centre in Toronto. In that capacity, it operated emergency electricity generators at the buildings for approximately 100 hours per year (consisting of 50 hours of testing and 50 hours of power interruption).