The appellant appealed a retail sales tax assessment on returnable wooden pallets for the period of 1997 to 2000, arguing that the tax was imposed retroactively by 2001 amendments and therefore interest should not be payable.
The Divisional Court dismissed the appeal, finding that returnable containers were subject to tax throughout the relevant period under the general taxing provisions and did not fall within the manufacturers' exemption, even prior to the clarifying amendments.
