Packing materials in manufacture may qualify as consumable stores only when evidence shows an integral, commercially expedient process.

Timber used for crates was discussed as a possible consumable store required in the manufacture of machinery where packing formed an integral and commercially expedient part of bringing goods into saleable form. The Court reiterated that manufacture may extend beyond the immediate production process if crating is necessary to preserve the machinery's precision and deliver it without affecting customer specifications. On the material before it, however, the issue remained factual and could not be determined for want of sufficient evidence, so the reference was left unanswered and the matter left for adjustment under section 69(4) after any further evidence.

---

---

Issues: Whether, on the facts placed before the Court in the sales tax reference, it could be determined that timber sizes used for making crates were consumable stores required in the manufacture of machinery, or whether the matter had to be left unanswered for want of sufficient evidence.

Analysis: The reference turned on whether packing the machinery in crates formed an activity so integrally connected with manufacture that the timber used for the crates could be treated as consumable stores required in the manufacture of taxable goods for sale. The Court reiterated that manufacture, in a commercial sense, is not confined to the immediate production process and may include an activity that is an integral and commercially expedient part of bringing the goods into saleable form. However, the Court held that the question was essentially factual and could be answered only if the record showed that such crating was necessary to preserve the precision of the machinery and to enable delivery without affecting the customer's specifications.

Conclusion: The Court declined to answer the reference on the existing material and left the Tribunal to adjust its decision under section 69(4) after considering the evidence that may be produced.

Ratio Decidendi: A sales tax reference involving whether packing materials are consumable stores required in manufacture cannot be answered in the absence of adequate facts showing that the packing activity is an integral and commercially expedient part of the manufacturing process.

---