What is the test for a sale in bulk for the purpose of resale?

We were referred to the case of Heath v. City of Victoria (1892), 2 B.C.R. 276, as supporting the principle that a sale in bulk was the sole test of a wholesaler. It dealt with a charge against a vendor of selling at retail contrary to a municipal by-law of a large quantity of trade circulars to one chemist to be used by the chemist for advertising purposes. While referring to many examples, the court found that the chemist, in effect, was reselling these circulars on credit and therefore the original sale by the accused was as a wholesaler. While it explored other possibilities, its ratio decidendi was that it upheld the principle of the test being that of a sale in bulk for the purpose of resale. I take it to be consistent with the other decisions that I have referred to.