In an application concerning hydro-electric property tax exemptions under section 3(1), paragraph 18 of the Assessment Act, the court determined that most disputed station components qualified as machinery and equipment used for producing electricity for sale to the general public.
The court rejected a narrow interpretation requiring direct transformation use and held all power produced at the stations met the sale-to-general-public requirement.
The court also held the applicant could not rely on paragraph 17 as an alternative exemption route.
Due conflicting expert evidence, the scope of exempt foundations required further expert process and a trial on that issue.