The following excerpt is from Cantire Products Ltd v. Ontario (Regional Assessment Commissioner, Region No. 15., 1991 CanLII 8259 (ON SCDC):
The case of The Queen v. York Marble, Tile & Terrazzo Ltd. (1967), 1967 CanLII 469 (SCC), 65 D.L.R. (2d) 449, [1968] S.C.R. 140, [1968] C.T.C. 44, can also be distinguished from the case at bar. It was a case under the Excise Tax Act, a federal statute. The Excise Tax Act refers to goods which are "produced or manufactured". The same words appeared in the Special War Revenue Act. The defendant imported raw slabs of marble which underwent nine specific steps in Canada before the finished marble product was sold to the public. No such raw material was used by Cantire in its rebuilding of old parts.
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