Words and Phrases - "produced"

After finding that marble slabs which were cut, reinforced and finished (through rough and fine polishing) 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 found that this view was confirmed by Schedule III to the Excise Tax Act, which referred to the production of cut flowers, straw, raw furs and wool not further prepared than washed, and by two Customs Tariff items, one of which referred to “marble, not further manufactured than sawn,” stating (at pp. 148-9, SCR):

In at least two recent decisions, the Court has considered the schedules to the Customs Act as being a revenue statute in pari materia and therefore an aid in the interpretation of words in the Excise Tax Act. In Bradshaw v. Minister of Customs and Excise, [1928] S.C.R. 54… Duff C.J., when considering the phrase “nursery stock” as used in subs. (4) of s. 19BBB of c. 8 of the Statutes of Canada, 5 Geo. V, pointed out that in the Customs Tariff the words used were “trees, plants and shrubs, commonly known as nursery stock” and in The King v. Planters Nut and Chocolate Company Ltd., [1951] Ex. C.R. 122, [1951] C.T.C. 16, Cameron J., at p. 130, said:

It is of considerable interest, also, to note that in the tariff rates under The Customs Act (which, as a revenue Act, I consider to be in pari materia), separate items are set up for fruits, for vegetables, and also for “nuts of all kinds, not otherwise provided, including shelled peanuts”. This would seem to indicate that in the minds of the legislators, nuts were not included in the categories of fruits or vegetables, and also that peanuts fell within the category of nuts.

When one calls in aid of the construction of the words “manufactured” and “produced” in s. 30(1)(a) of the Excise Tax Act, the provisions of the Customs Tariff, items 306(b) and 306(c)…it would appear that the legislators regarded mere sawing of both building stone and marble as being the manufacture thereof. I view these considerations of both the exemptions in Schedule C of the Excise Tax Act and the items in the Customs Act as being confirmatory of my view… .