Kodak (Australasia) Pty Limited v The Commonwealth of Australia & Anor; The Commonwealth of Australia & Anor v Genex Corporation

Case

[1992] HCATrans 101

No judgment structure available for this case.

,

~

IN THE HIGH COURT OF AUSTRALIA

Office of the Registry

Sydney Nos Sl36, Sl37 and Sl38 of 1991

B e t w e e n -

KODAK (AUSTRALASIA) PTY LIMITED

Appellant

and

THE COMMONWEALTH OF AUSTRALIA

THE COMMISSIONER OF TAXATION

Respondents

Office of the Registry

Sydney No Sl34 of 1991

B e t w e e n -

THE COMMONWEALTH OF AUSTRALIA

THE COMMISSIONER OF TAXATION

Kodak(3) 1 7/4/92
MASON CJ
BRENNAN J
DEANE J
DAWSON J
TOOHEY J
GAUDRON J
MCHUGH J

Appellants

and

GENEX CORPORATION PTY LTD

First Respondent

RABBIT PHOTO (SA) PTY LTD

Second Respondent

RABBIT PHOTO (WA) PTY LTD

Third Respondent

TRANSCRIPT OF PROCEEDINGS

AT CANBERRA ON TUESDAY, 7 APRIL 1992, AT 10.19 AM

Copyright in the High Court of Australia

MR D.M.J. BENNETT, QC:  In the first of those matters, if

the Court pleases, I appear with my learned friend, MR B.J. SULLIVAN, for the appellant. (instructed by

Mallesons Stephen Jaques)

MR I.V. GZELL, QC: If the Court pleases, in the first of

those matters, I appear with my learned friend,

MR A.H. SLATER, for the Commonwealth and the

Commissioner of Taxation and for the appellant in

the second of those appellants. (instructed by the

Australian Government Solicitor)

MR D.H. BLOOM, QC:  May it please the Court, I appear in the
second matter with my learned friend,

MR B.J. SULLIVAN, for the respondents. (instructed

by Blake Dawson Waldron)

MASON CJ:  Mr Bennett.
MR BENNETT:  If the Court pleases. Your Honours, I hand up

an outline of submissions. I also, Your Honours, because of the complexity of the matter, have had

prepared a second document entitled appellant's
submissions, which gives a much more detailed

version of our submissions.

MASON CJ: Yes, Mr Bennett?

MR BENNETT: If I can just give Your Honours a guide to the

way these have been set out. The six points of law
are set out in the outline. In substance there are
probably five rather than six. The lengthier
Kodak(3) 2 7/4/92

document has a number of pages of background at the

beginning, then it goes on to deal with the six

submissions separately.

Then at the end, on pages 11, 12 and 13, it

sets out the six submissions again with a summary

in each case of what is contended for by the

taxpayers and the Commissioner and what was found

by the Court of Appeal and the Federal Court on

each issue, as well as what one might colloquially

call a mud map of how the submissions fit together.

We have done it in terms of:  "If yes, go to

2; if no, go to 3", and so on. Your Honours will

not need to worry about those "go to" commands

until Your Honours have reached conclusions on the

questions. It is just a convenient way of working
out what arises and what does not and how one gets

to a result.

Your Honours, there are two other preliminary matters before I start.

The first is that my

learned friend Mr Gzell has provided for the Court

a ·volume of legislation and some explanatory

memoranda and so on on which he will be relying,

and that has conveniently been placed before

Your Honours. We are indebted for that assistance.

There are two volumes, apparently, which he has provided.

The second matter is this, that I propose in

the course of the morning to make an application

for leave to amend my notice of appeal by adding a

short additional matter. The short additional

matter is a matter which cannot be argued before

Your Honours because it is a constitutional point,

of which notice has not been given.

I propose to explain to Your Honours, (a), why

we are in the position of doing this and, (b), why

in any event, it will not affect Your Honours at

all.

The reason we are in the position is that the point arises as a result of the decision in Mutual

Pools; the point came to our attention last

Friday - we have been considering it since

then; the point was apparently reserved by Genex,

by the respondent to the other appeal, in the

Federal Court because, of course, the proceedings in the Federal Court are a stated case, and the point was reserved so that, if Your Honours decide

in favour of the Commissioner in that matter, they

still have the point available to them. We, as I
say, were not aware of the point until Friday. We

simply wish to be in the position that if Genex can

argue it in the Federal Court, so can we.

Kodak(3) 3 7/4/92

It only arises in a particular combination of

answers to the other questions, and it may well

be - and I will explain that to Your Honours

perhaps at the end of the argument rather than

before it. So, it is probable that it will not

arise in any event. What we would be asking

Your Honours to do if leave is granted is simply to

adjourn that issue at this stage and then, if it

arises on Your Honours' decision, to make an order
remitting it to the Federal Court so that we, at
least, are in the same position as Genex in

relation to the point if it is ultimately to be

argued in the Federal Court.

The point is - and I can explain it very

briefly in one or two sentences - that if the

negative is not new goods but is deemed to be for
the purpose of the sales tax legislation so that a

tax is imposed on the development of the negative

after it has gone into consumption as the property

of the customer, then the tax is a consumption tax,

or at least a tax imposed after the goods have

reached the end of the excise chain and, therefore,

in the Mutual Pools principle, under section 55,

cannot be in the same Act and cannot be placed in

it by a deeming process.

As I say, it only arises on a certain

combination of answers and we will not be asking

Your Honours to deal with it but merely to remit it

at the end of the day. I propose to make the

application formally at the end of my submissions

so that Your Honours will be in a better position

to see where it fits into the overall argument.

The facts of the appeal are in a very short

compass and are not in dispute and the only reason

I need to go to them is to explain the terms which

are used which appear in the background at the
front of the detailed submissions. I have

underlined the four terms which I will be using.

One starts with unexposed negative film, which

is purchased from a retailer and, at the

appropriate point in the prior chain, a first sales

tax is exacted on that. No problem arises in this

case in relation to that tax.

The customer then exposes it in his camera and

it becomes exposed negative film. It is then
delivered to us where its surface is subjected to a

simple chemical process; it was described in the

evidence in both cases, while obviously in
different terms there is no difference in substance

between the way it was described. It involves the removal of a small part of the surface, the fixing of certain other chemicals on the surface and the

Kodak(3) 4 7/4/92

addition of certain elements and, ultimately, one

has the familiar photographic negative. That is

known as the development of the film.

The negative - and it is important to realize

that it is always the customer's property - is then

used by us in a process under which light is shone

through it and that is done on to a piece of

sensitized paper which is then manufactured into a

print. There is no dispute, again, that sales tax

is payable on the sale by us to the customer of the

print.

The problem which arises in this case is that

the Commissioner claims that there is a third sales

tax. What he says is that the process of

development of the negative constitutes

manufacture, either under the general law or under

an extended part of the definition, which I will

take Your Honours to. Therefore, he says, there is manufacture and the negative is then either applied

by Kodak to its own use, although it is not its

goods, and that raises the problem Your Honours

left open in State Bank recently, or when it is

given back to the customer there is a deemed sale

under section 17A of the Act, and section 17A,

without taking Your Honours to it now, simply says

that if a customer gives goods to a manufacturer

which he makes up and the manufacturer then gives

them back to the customer, even if the goods remain

the customer's property there is a deemed sale so

as to pick up a sales tax, and the Commissioner

says, by one or the other of those two ways, he is

entitled to the tax. In other words, what he is

seeking to do ultimately is to treat the Act rather
like a VAT, or as it is now being called in

Australia, a goods and services tax. The idea that

one looks at each stage and to make the system work

one has to have every stage covered by the tax.

Now, I referred Your Honours to an amended

definition. That appears at the top of page 2,

where in 1986 the definition of "manufacture" was

amended by adding the words saying that manufacture

includes, in effect, the development of exposed negative film into a negative. So we are faced with the fact that there is a deemed manufacture

which there takes place.

I propose now to go to the six detailed

submissions, the six questions and deal with them each in vacuo and then at the end of the day show

Your Honours how they fit together. But, it is

probably easier, because of the volume of

provisions one needs to look at, to look at each

one as a separate question at this stage.

Kodak(3) 5 7/4/92

The first submission on the top of page two,

is that the development of exposed negative film

into a negative is not "manufacture" within the

ordinary meaning of that word. Now, I can be very

brief about this submission, because both
Full Courts were in my favour on it and in a sense

it is, although we have not had a formal notice of contention, we have little doubt that my friend is

going to argue this. In those circumstances, I do

not propose to, as I say, take Your Honours to it

in detail, but merely to show Your Honours how the

point arises and what the point is.

There is a line of cases in both England and

Australia where the courts have tried to draw a

line between two concepts: one is the alteration of

existing goods, which of course is not manufacture,

and one is the manufacture of new goods, which of

course is, and as Your Honours can appreciate,

there are many situations where there is a border

line. The best known cases are the three I have

mentioned there, which Your Honours need not go to.

In Jax Tyres it was said that retreading tyres was

not the manufacture of new goods. In McNicol

v Pinch, which is the leading case in England,

there was a product called "330 Saccharin", which

had some minor impurities in it and therefore did
not have the sweetness of totally pure saccharin.

By making it more pure and taking out some of the

impurities, one converted it into "550 Saccharin"

and that process was said not to be manufacture. There is an interesting dissent in that case

by Mr Justice Ridley and the point of

His Lordship's judgment is that one cannot answer

the question merely by looking to the words used.

In other words, His Lordship expressed the view in

his dissent that the majority judgment was simply

based on saying, well the word "saccharin" is used

both times, therefore it is not manufacture. The
majority, in fact, went much further than that, but of course, the mere use of words cannot control one
way or the other. We use the words "exposed

negative film" and "negative" and we say, well it is really the same thing. The Commissioner would say, no they are two completel'y separate types of

goods. But one does not really answer that by
saying, is there a different word for them? One
has to go a little deeper than that.

An example the other way is Jack Zinader,

which is of course one of the leading cases in

Australia, where reconditioned fur coats were held

to be the manufacturer of new goods. The customers

brought in their old furs, they were cut up, resewn

and made into different coats, I suppose. The
Kodak(3) 6 7/4/92

Court held that as a matter of degree, that was on

the other side of the line.

Here, the process is a chemical process. It

results in a removal of a very small part of the
surface of the exposed negative film and the fixing
of certain things on it and the addition of certain

chemicals, but the bulk of the object is the same.

It has, of course, some different properties. One

could not shine light through the exposed negative

film to make a print directly, although there is a

procedure which Polaroid, I believe, uses which

does something similar to that, but we are not

concerned with that procedure in this

case.Certainly the type of film we are talking

about here, the evidence is it cannot be treated in

that way; one must go through the intermediate

step.

In Jack Zinader, there were a number of

phrases used. Mr Justice Williams used the phrase,

"goods of a different character", and

Sir Owen Dixon used the phrase, "he cannot be

treated as having altered an existing thing without

producing a new one". What we say and what we said

below, and what appears to have been accepted, is

that this case in a sense is in a unique category,

which makes a lot of these cases - and if number of cases in the digests where things have

been held to fall on one side or the other of the

line. We do not think they help very much.

There is one distinction in this case from

every other one of these cases, and that is that this is a case where the goods were simply going

through a process for which they were always

intended as part of their use. In other words, if

one looks at the piece of unexposed negative film

when it is sold to the customer at the very first point in the chain and one says to the customer, "What are you buying this for?", the customer's
answer, assuming he gives a careful and considered
answer, will be, "I am buying it so that it can go
through a process. That process will have three
main steps. The first is that I will point my
camera at something and press the shutter. The
second is that Kodak will develop the exposed
negative film into a negative, and the third is
that they will shine light through it so that I
have a print. It's really the print that I want.
That's the purpose of the whole exercise".

In that sense, our submission is, ultimately,

that the reason this is not manufacture is it is

part of the process of consumption which is the

very process it is bought for. It is what it is
Kodak(3) 7/4/92

always intended to go through. If I wanted to take

perhaps a very remote analogy to demonstrate the
point, one does not say that a caterpillar, when it

becomes a butterfly, is becoming a different

creature. It is simply going through a process it

was always destined to go through as part of its

existence and when the caterpillar was born, one of

the things it was born for was to become a

butterfly.

This is not a case of some new object being

made which has any different commercial

significance. In all the other cases, whichever
side of the line they fall on, one can say perhaps

there is some difference of commercial

significance. The new tyre, no doubt, has a

c:.; f ferent commercial value in significance to the

_d unretreaded tyre that is worn ·)ut; the new fur coats and the old fur coats, similarly. The

purified saccharin may have a different price or

value or commercial purpose than the old saccharin,

and one can say that in all the other cases.

But here, one has something which is simply

two steps in a process. It is not that the exposed

film has a different purpose or commercial value

than the negative. Its only purpose or commercial

value is to become a negative. There is nothing

else you can use it for, and that feature is
different in the other cases. It is certainly

different in Jack Zinader, which is the leading

case the other way. There were things that could

be done with old fur coats other than cutting them

up and making them into new fur coats. But here

you have an object which is really just a slightly

earlier developmental stage of the same object.

As I say, that argument succeeded in both Federal Courts and it is up to my learned friend to

challenge it, but that is the way we put it. The
reason it is the same object is the purpose of

reason. If one does look to the other reason, and

I will not spend any time on this, if one does look

to the question of degree of alteration, we say

here when Your Honours read the evidence there is a

fairly minor degree of alteration, and there is an

affidavit by Mr Forbes, who is a chemist employed

by Kodak, who describes the process, and if

Your Honours skim through that Your Honours will

see that what happens is that there is a fairly

minor series of chemical changes which are effected

to it. That is the first of the six points.

The second point depends upon the first being

answered adversely to my submission. It was not

considered at all by the Court of Appeal although

it was argued in the Court of Appeal and written

Kodak(3) 7/4/92

submissions were put in in relation to it; and my

friend concedes that. I have the written

submission if Your Honours wish to see them but

there is no advantage because my friend agrees it

was put to the Court of Appeal.

The Federal Court, again, accepted the taxpayer's argument on this point.

And this point

arises in this way: would Your Honours please go

to the black sales tax volume which I believe

Your Honours have. The starting point is the

definition of "goods" and that is at page 92,141.

Your Honours see that there is an exclusion in

paragraph (a):

goods which have, either through a process of

retailing or otherwise, gone into use or

consumption in Australia - The reason for that - as Your Honours will

appreciate and I will come to in more detail

later - is that in the first of the big sales tax

cases, in Ellis & Clark, the Court held that

secondhand goods or goods which had gone into use

or consumption - the phrase is used in the case -

were not subject to sales tax and this provision

was put in substantially to embody the decision in

that case.

One then goes to section 17A, which appears on page 92,222. That provides:

Where -

(a) goods have been manufactured in Australia

by - Kodak for the customer -

(b) the goods were manufactured in whole or in

part out of materials supplied by the

customer -

if we are assuming question 1 against me, those two

conditions are satisfied because the goods are

manufactured, the goods being the negative which is

said to be manufactured from the exposed negative

film, Kodak shall -

for the purposes of this Act, be deemed to

have sold the -

negative -

to the customer at the time when the -

negative is -

Kodak(3) 9 7/4/92

de .vered to the customer .... and the customer

s l ..... be deemed to be the purchaser -

So, although the negative is at all times the customer's goods, although he has paid for them -

he has paid for the negative when he or she bought

the unexposed film - this section deems the goods
to be sold to the person who is, in fact, their

owner and the sale takes place at the time when the

goods are delivered back, when we hand back the

negative with the print~

If Your Honours now go back to section 17, two

pages back, it is 92,214, that provides that:

sales tax ..... shall be levied and paid upon

the sale value ~ goods manufactured in

Australia by a saxpayer -

and then one of three things happens -

sold by him or treated by him as stock for

sale by retail or applied to his own use.

And the argument is these goods have been

manufactured, they are then deemed to be sold by

section 17A, so they are sold back to the customer

and therefore sales tax is exigible. The fallacy

in that argument, which Mr Justice Hill and the

Full Federal Court upheld and which the Court of

Appeal did not consider, is a very simple one. The
negative, after it was manufactured, on the

assumption we are making, had light shone through

it to make a print. It has thus gone into use or

consumption in Australia. It is therefore no

longer goods and it is not goods when it reaches

the taxing point of the deemed sale to the customer

when it is given to him. The point is as simple as

that.

May I make good the submission that the

shining the light through it is going into use or

consumption. Common experience will tell one that

although a negative is normally returned to a
customer and in the cases we are talking about, it

is returned to the customer, no doubt for the

purpose of having further prints made if the

customer wishes, in practice it is obvious that in,

I suppose, whether it is 99 or 99.9 per cent of the

cases, the negative is either thrown away or left

to languish in a top drawer until it is thrown away

many years later. No doubt all of us have top

drawers full of old negatives.

There is the theoretical purpose that if the

unusual customer wishes he can take it back and

have fresh prints made from it and that may happen

Kodak(3) 10 7/4/92

occasionally and it is, no doubt, the reason the negative is given back to the customer. But the

primary purpose, the real reason it was brought
into existence, the reason the customer was

prepared to pay the cost of having it brought into

existence, was to make that initial print, or pair

of prints if two are made. That is really all it

was brought into existence for. If one had to

apportion its raison d'etres; if one had to
apportion why the thing was made, one might say

something under one per cent, if common experience

is right, is so someone can make more if he wants

to and have the negative in his top drawer, but the real reason is to make the print the customer wants

initially.

That is so far and away the predominant reason

as to make anything else insignificant, and it has

already had that reason happen to it before the

customer gets it; before it reaches the taxing

point. So if "use and consumption" means anything,

it must mean that. Looked at a little differently,

if one, assuming that it is a very small proportion

of customers who ever want a further negative, no

doubt if one were to say to customers, how much

less would you be prepared to pay if you do not get

the negative, no doubt the answer would be, very

little indeed. No doubt, in most cases, the

negative is a fairly unimportant piece of material

which will clutter up top drawers. Its importance

is it had to be made so that the print could be

made; once that is done, it is a fairly valueless

piece of plastic, in most, except the very few

cases where the customer actually wants more

prints.

So the submission simply is, whatever "use or

consumption" means, it must mean this. Of course,

the phrase is not an hendiadys; the phrase is one

which has two elements and it is, on any view of

it, quite clearly use. And it is not a minor use

for the reason I have given. It is true that the

use does not damage it; that is true, but, on the

other hand, it is a use which really uses up almost

all of the value and purpose that it has.

DAWSON J:  And the effect of this is that it is deemed to

have been sold to the customer, but in effect it is

second-hand goods, ..... unsold.

MR BENNETT:  Yes, but we would say in any event that is so;

it is clearly second-hand goods.

DAWSON J:  And therefore does not fall within section 17.
MR BENNETT:  Yes. I do not need to use the words

"second-hand goods" though, Your Honour, or to

Kodak(3) 11 7/4/92
confine myself to that. The statutory phrase is

"use or consumption" and that is the phrase on

which we rely. Now, it may be one way of

justifying my position is to say, what the section

means is second-hand goods and these are

second-hand goods, but even if one were to say,

these are not second-hand goods in the ordinary

sense, we would say it is still clearly "use or

consumption", and as I say, the Full Federal Court

supported that and the Court of Appeal did not deal

with it, but in our respectful submission, should

have.

The third submission is one with - - -

DEANE J: There is no definition that says, delivered

includes applied to the use of the customer?

MR BENNETT:  No, Your Honour, there is no definition of

"use" or "consumption".

DEANE J: Well, "delivered" would be the operative word.

MR BENNETT: Yes. There is no definition there,

Your Honour.

BRENNAN J: Is it perfectly clear that "goods" has the same

meaning throughout 17A? The thing that is

manufactured would be goods at that time. It is

only when you shine the light through them that

they cease to be goods, is that not so?

MR BENNETT:  Yes, Your Honour

BRENNAN J: Therefore you fasten on the time at which the

goods are delivered to the customer, which is after

the light has been shone through.

MR BENNETT:  Yes, Your Honour.
BRENNAN J:  What does the deeming relate to?
MR BENNETT:  The deeming, Your Honour, is for the purpose of

fixing the taxing point under section 17. Section

17 identifies three taxing points.

BRENNAN J: But are the goods which are deemed to have been

sold the same goods as those which are

manufactured?

MR BENNETT:  Yes, Your Honour.
BRENNAN J:  Do they lose their character as goods from the

time of manufacture under 17A to the time of

delivery under 17A?

Kodak(3) 12 7/4/92
MR BENNETT:  Yes, Your Honour, they can, and in this case
they do. Suppose they were destroyed during that

period, suppose we did not give them back to the

customer but destroyed them, there would be no

deemed sale.

BRENNAN J:  So goods in paragraphs (a) and (b) may be goods

for all purposes of the Act and, though it is the same substance, it ceases to be goods at the time of delivery.

MR BENNETT:  Yes, Your Honour, in this case they do and they
can. May I just put to Your Honour in perhaps a

little more detail the example I just put to

Your Honour. Suppose we say, "We won't give you

your negative back. We will destroy the negative or perhaps even melt it down and use it for fresh unexposed film" - if that is possible - "but it is

destroyed as goods". If one then reads

section 17A(l), one gets this position: a negative

has been manufactured in Australia by Kodak for a

customer. It was manufactured out of materials

supplied by the customer. The manufacturer, Kodak,

is then deemed to have sold the goods at the time when the goods are delivered to the customer. If the goods are never delivered to the customer,

there is never a deemed sale. The phrase of course

is, "the goods were delivered''. It assumes that

the goods are delivered to the customer.

The purpose is to create a deemed sale, not

where the customer provides goods which are used
and then destroyed, but used for the customer's

benefit in some way by the manufacturer, but rather to create a deemed sale where he actually gets them

back in their improved state and pays for them.

There is nothing surprising in the result in this

case once one assumes that the negative really has very little value to the customer, and certainly a value a good deal less than the cost of producing

it, because the real value of the cost of producing

the negative is so the light can be shone through

it to make that first print.

That is the real reason it is done, that is

the real value. While there may be a small

residual value for a residual purpose, it would be

surprising if the cost of the development of the

unexposed negative film were made taxable as if

that were part of the value of the goods delivered

back to the customer. So it is really in

accordance with common sense that goods should have

the same meaning throughout section 17A.

BRENNAN J: That is not - perhaps if I have not made my

point clearly enough, that may not be in your

favour if it has the same meaning throughout in the

Kodak(3) 13 7/4/92

sense of the same denotation as distinct from
connotation. If it denotes the same substance

throughout, you have goods at the point of

manufacture falling within the Act. If the term

"goods" used in reference to the delivery is that

substance, then it matters not what has happened to

them after the point of manufacture, those goods

have been delivered and the deeming operation takes

effect.

MR BENNETT:  I follow what Your Honour is putting to me. My

submission is that the point on which section 17A

substantially fixes is the taxing point, not the
conditions. Paragraphs (a) and (b) are merely
preconditions. It is of less importance for the

purposes of the Act that they be goods at that

stage. The key to the section is, at the moment

you give the goods to the customer there is a

deemed sale and the conditions for that occurring

are that something has happened before. So,

although grammatically the conditional clause

appears first, it is really a subsidiary clause.

The substantive clause is the first two lines of the long paragraph, so that is the point where we

would submit they have to be goods. Whether or not

there have to be goods at the earlier stage does

not, perhaps, matter.

One reads it, in other words, as if the

section read this way, "A manufacturer who delivers

goods to a customer shall be deemed to have sold

them to the customer at the time of delivery if",

and then (a) and (b), and that is really what it

means.

There is a second answer to Your Honour

Justice Brennan's question, and that is that the

primary operative provision is not section 17A but

section 17, and the tax is only levied if:

the sale value of goods manufactured in

Australia by a taxpayer and sold by him -

so there must be goods sold by him and that means,

again, it is the deemed sale to which one has

looked. It is the moment of the deemed sale when

there must be goods. Indeed, one wonders,

otherwise, why section 17A has made the point about

time and specifically said, "at the time when the

goods are delivered to the customer". That, we

submit, is for the purpose of emphasizing that that

is the crucial moment for all purposes under

section 17A as it is under the primary provision of

section 17.

Of course, if I were incorrect in this, we

would concede the tax would be exigible, assuming

Kodak(3) 14 7/4/92

there is manufacture if we do not make prints. In
other words, if a customer comes to us, as no doubt
some customers may, and say, "I just wish you to

develop this exposed negative film for me and give

me the negatives. Do not bother to make a print, I

have got a light in my own studio and I can shine the light through it myself", now if the customer

says that to us then, of course, section 17A would

deem there to be a sale. That is the case where

the negative has not gone into use or consumption

in Australia. But where we perform the whole

process it is brought into existence for and then

happen to give it to the customer, the fact that we
happen to give it to the customer rather than

destroying it should not be the occasion for the imposition of the additional tax. Your Honours, that is the second of the six questions.

The third question goes back a step. We are

now looking at deemed manufacture and Your Honours

recall that the 1966 amendment, which Your Honours

can see in all its glory on page 92,142,

"manufacture" includes, in paragraph (d):

the processing or treatment of exposed

photographic or cinematographic film to
produce a negative.

Now, the problem is that, let it be assumed that we deem what occurs to be manufacture, what

the legislature has not done is to amend the

definition of "goods". "Goods" are defined so as
to exclude: 

goods which have ..... gone into use or

consumption in Australia.

On any view of it this object which started its

life as an unexposed negative film and has now been

exposed by the customer and developed, has gone

into use or consumption in Australia, within every

meaning of that words. It has been purchased by an
ultimate consumer. He has put it to the only use

to which he can put it, or she can put it, by using

it in the camera. It has been exposed. In every

sense of the word, if one looks at the exposed
negative film, immediately after the customer has

taken the customer's picture, one has, in every

sense of the words, used goods and, indeed, goods

of no value to anyone else. It is well and truly

goods which have gone into use or consumption in

Australia. Now, deeming something to be a

manufacture cannot also deem the negative to be

something which it is not. It cannot deem it to be
goods.
Kodak(3) 15 7/4/92

It is simply a case where the legislature, if

it wished to achieve the result that it caught the

goods which we are concerned about in this case, it

needed to amend the definition of "goods" as well

and say, as a qualification to paragraph (a),

"except in the case of negatives". The negative

simply is not goods. It has gone into use or
consumption in Australia long before the light has

shone through it.

DAWSON J: It is really only a slight variation on the

previous submission, is it not?

MR BENNETT:  The previous submission did not involve any

problem about what the legislature intended by

making the amendment; this submission does. This

submission involves a partial misfiring of that

intention. Assuming I am right in our first

submission that it is not manufacture at common

law, the legislature has succeeded in making this a

manufacture and if the negative is then delivered

to the customer without a print being made from it

- I am sorry, I withdraw that. The legislature has

not succeeded, no. It has failed because the

negative is goods which have already gone into use

or consumption in Australia and, therefore, it has,

on this submission, totally failed in its

intention.

BRENNAN J:  I suppose another way of putting that is that

what is manufactured are the goods which are

referred to in paragraph (a) of the definition of

goods.

MR BENNETT: Yes. What the Federal Court said - and I will

come to the Federal Court argument in a moment, I

wish to deal with the Court of Appeal first - was, "Well, you read the word 'goods' in paragraph (a),

in the exclusion, as meaning or as including, at

least, something which is deemed to have been

manufactured. "

I have given an example on pages 4 and 5 which

those of Your Honours who heard the leave

application have already seen. I will not spend a

lot of time on the example, it simply illustrates
the type of misfiring which we say has occurred in
this case and it shows that there are cases where

parliamentary intention is not the whole of the

answer.

An example we give is this: you have

legislation which says "No person shall drive an

unlicensed vehicle on a public highway". There are

detailed provisions for licensing vehicles and

vehicles are defined as cars and trucks. The

effect of that Act is that the licensing scheme is

Kodak(3) 16 7/4/92

enforced by paragraph 1. Paragraph 1 is the

operative provision which enables it to work. If

you did not have paragraph 1 the licensing scheme

and the definition would both be quite pointless

because it would not have any effect.

Assume Parliament then, because of complaints about refrigerators contaminating food or being

left on garbage dumps and having children enter

them, decides that all refrigerators should be

registered and controlled in the same way as motor

vehicles but it is concerned about the cost of

setting up a registration procedure, so it says,

"We'll use the motor vehicle registry and we'll use

the Motor Traffic Act and we will just define

'vehicles' by adding the words 'and

refrigerators'." So that we now have a licensing
system for refrigerators. And all the second

reading speeches and all the explanatory memoranda

say "The purpose of this legislation is so that we

can treat refrigerators like motor vehicles and

have the benefit of the registration provisions

that have been so successful for motor vehicles at

a very small extra cost to the government."

And assume that Parliament forgets one thing:

it forgets, in doing that, that the operative

provision is "no person shall drive an unlicensed vehicle on a public highway", and no one drives a

refrigerator at all, let alone on a public highway.

So, the primary operative provision is going to

have no effect. The result is, people are going to

be able to ignore the provision about registering

their refrigerators, because the provision which

provided the whole means of enforcing it and made

it work, just is not there.

Now, the court is not going, in that case, to

say, "Well, we see what the Parliamentary intention

was, we know what Cooper Brookes said, let us see

if we can, in some way, effectuate Parliament's

intention; let us read the words "drive on a public

highway" as meaning "store food in in one's

kitchen". Now, clearly no one is going to do that.

It is an example of a case where the intention has

misfired. I have not put this case on my list, but

I have given Your Honours an example of a case

where tax legislation did misfire, an English case

of Birmingham Corporation, where it is discussed.

But it misfires because they have amended a

definition provision, but have not made a

consequential amendment which has to be made. It

is not like Cooper Brookes. Cooper Brookes was

concerned with the procedural problem where one

section picks up a reference to another section and

does not say, as it should say, mutatis mutandis,

and the wrong subparagraph was referred to.

Kodak(3) 17 7/4/92

It is much easier in that case for the court to say, by a very slight extension of the law in

relation to construction of statutes, that one can

take a benevolent approach. After all, in

construing contracts, the courts have always said

that one can delete or add the word "not", where

there is an obvious mistake. Your Honours recall

the cases on that, where someone has the word "not"

in a provision and it is absolutely clear that the

word "not" was not intended to be there. The

process of eliminating that word "not", is not a
process of rectification; it is a process of

construction. Fitzgerald v Masters is the leading

example. The court says it is quite clear what was

intended. Fitzgerald v Masters was the case where
the terms of the Real Estate Institute form were

incorporated, but "only to the extent that they are

inconsistent herewith" and, as a process of

construction, the court says, that means

"consistent herewith''; it is an obvious draftsman's

mistake.

Now, that is really all Cooper Brookes stands

for. The omission of mutatus mutandis, or the

referring to the wrong subparagraph number, or the failure to refer to an additional subparagraph,, is

an easy mistake to cure by analogy to that sort of

rule. But that is very different here; here one
has to go much further. Here, to achieve the

legislative intention, one has to say - and when

something is manufactured, the result is deemed not

only to be goods but to be goods different from

what it is manufactured from, because if one does

not say that, it is goods that have gone into use

or consumption in Australia. And, in our

respectful submission, for that reason, the

Court of Appeal was wrong.

Now, the Full Federal Court - I am now on the

bottom of page five - dealt with the matter

slightly differently, as I have indicated, and it

rejected this argument on the basis that it took

the word "goods" in paragraph (a) of the exclusion

in the definition of "Goods" on page 92,141, and

said, "Well, that must be taken as including

something which is deemed to have been

manufactured, and if something is deemed to have

been manufactured, it is 'goods'". We would submit
that that simply does not get one there. When one

deems something to be manufactured, one does not

necessarily apply a consequence of deeming. If you

deem a boat to be a motor vehicle, you do not also

deem it to have wheels because all motor vehicles

have wheels. When one deems something to be

manufactured, one does not thereby deem it to be

different goods from what occurred before. The
deeming stops at the definition and the only
Kodak(3) 18 7/4/92

purpose of the definition is, that where one sees

the word "manufacture", one regards this process as

a manufacture, but it does not go to the next step.

And, for those reasons, we submit that the

amendment does not achieve that result.

I might just jump ahead and deal with the

sixth point now before I come to 4 and 5, because

the sixth point is really a combination of the last

two matters I have put to the Court, and it does

not involve independent argument.

The sixth question applies the new definition

of manufacture to the second stage, the shining the

light through, and it says "Well, even if the Full

Federal Court is right, and the Court of Appeal is right, in saying, 'At the end of a process of

deemed manufacture you must have something that is
deemed to be goods', even if that is so, you still

have the problem that those deemed goods go into

use or consumption in Australia when the light is

shone through them."

In other words, the second stage, which takes

it out of the definition of goods, applies equally

to the deemed goods which the negatives are, if my

third submission fails. And one can make this

comment about that point: if it is wrong, if I am

wrong in what I put to Your Honours, these deemed

goods are different to all other goods and all

other deemed goods which one could imagine, because

unlike anything else they can have virtually the

whole of their use and consumption take place and

yet remain goods, although nothing else can. And

nothing in the Act suggests that.

I simply remind Your Honours also that this

submission does not involve a misfiring of the

legislation because, again, if one has the

situation where the customer merely asks to have

his negatives developed, his exposed negative film

developed, and does not want a print, then this

argument would not be available and the sales tax

would be exigible.

When one thinks about it, that is in

accordance with common sense because that customer

is buying something valuable, that customer is

getting what he wants, he is getting his negative,

which was the reason he had the exposed film go

through the process. Unlike the customer who gets

his prints, which is what he really wants, and

happens to have the negative in case he wants some

more, this customer is getting something which is

worth, to him, the full cost of development. In
relation to the other customer, of course, the

value to him is something significantly less than

Kodak(3) 19 7/4/92

that cost of development; that value is in

something else.

So the sixth argument then is that even if one

relies on the deeming and one says this is a deemed

manufacture, one still has argument 2 available,

and parliamentary intention simply does not defeat

that. First of all, Parliament is never shown to

have intended to create this special class of goods

which remain goods notwithstanding going into use

or consumption; and secondly, the parliamentary

intention works perfectly in the case where it

should work, namely, where the customer is buying

something which has, to him, the whole value of the

cost of production.

DEANE J: That assumes, does it not, that if you be wrong on

the effect of the "deeming" and the relevant goods are the treated exposed negative, that the treated exposed negative was not put to the manufacturer's

use when he used it to produce the print?

MR BENNETT:  Yes, it does, Your Honour, because that is the

argument to which I am now corning. That is why, if

Your Honour goes to - - -

DEANE J:  I was looking at your mud map, as you called it.

It said if you succeeded on the manufacture point,

you go straight to 6, but that does not seem to be

so. Do not take time with it now.

MR BENNETT: It may be, Your Honour, that one has an

additional loop, that if one goes by that route

to 6, one has to go back to 4 and 5.

DEANE J:  You still have to exclude the "to his own use".
MR BENNETT:  Yes, I do. We had quite a lot of trouble

trying to construct that, and it may still have

defects in it, because there are different ways one

gets to some numbers which may have different
results for earlier numbers. Your Honours, the

remaining two submissions deal with the application

to "own use". The contention is made against us,

although both courts again decided it in the

taxpayer's favour, that Kodak, when it shines the

light through the negative, is applying it to its

own use.

The application to "own use" is the third of the three taxing points in section 17.

The classic

case that is always given in examples when one

talks about this provision is the manufacturer of

light globes who takes one light globe out of light

globe producing machine at the end of the day and

screws it into a socket directly over that machine

to illuminate the machine while it produces more

Kodak(3) 20 7/4/92

light globes. That, I suppose, is the classic case

of a manufacturer who takes a product and applies

it to his own use. One could no doubt think of

numerous other examples.

In the State Bank case, it was put on behalf

of the Commissioner in that case that one could
apply goods to one's own use even if they were not
one's own goods. The Court did not need to decide

that question and it expressly left it open. So

the question now arises again. There are of course

numerous examples in the authorities of application

to "own use", but one thing which is significant,
and particularly significant for the purpose of the
present case, is that in three of the leading

cases, the application to "own use" consisted of

parting with ownership.

If Your Honours recall the facts of Max

Factor, Hornibrook and Taubmans, that was so in

each of those cases. In Max Factor, cosmetics were

applied by the manufacturer to its own use by

giving them away as samples. In Taubmans, the

paint cards, the plastic cards which showed all the

different shades of colours of Taubmans paints,

were applied to Taubmans' own use by being given to

retailers to show them to customers in their shops.

In each case of course, it was the giving away the

object in the promotion of the manufacturer's trade

which was applying it to its own use.

Hornibrook is another example. There the

concrete piles, which no doubt one can still see
when one crosses the Brisbane River, were applied

to Hornibrook's own use by being fixed into the

ground, thereby becoming fixtures and becoming the
property of the owner of the realty - one assumes
the purchaser of the bridge - but in each case it

applied it to its own use by disposing of it.

That, of course, is not the only way one can

apply goods to one's own use, but the fact that a

form of application to one's own use involves the
disposition of property in the goods suggests very

strongly that one can only apply goods to one's own

use if they belong to one. Of course, in the

normal case, application to "own use" will consume

the goods, or at least make them second-hand. If
the light globe is unscrewed from the ceiling over

the machine and sold as stock, no doubt it should

be sold as second-hand goods and, no doubt, it is

goods which have gone into use or consumption in

Australia and therefore excluded, so there is no

second sales tax when that _ight globe is then sold

on to the customer.

Kodak(3) 21 7/4/92

In all the other examples, in the QTAB case,

of course, the various forms and documents were
applied to the TAB's own use by being, in some

cases, pinned to notice boards and then becoming

defunct when the meeting was held. In other cases,

when there were forms being filled in and used as

forms, the application to "own use" was something

which depended upon the documents being in the

ownership of the party concerned.

There is no case where goods not the property of the manufacturer have been said to be applied to

its own use and, in our respectful submission, in

no sense does the manufacturer apply these
negatives to its own use. It applies them, if
anything, to the customer's use. It may expose
them to a use, and we say it does, but it is not
its own use, it is someone else's and the reason

for that is that it is the customer's negative; it

is simply not the manufacturer's negative.

The other way one gets to the same result is

by looking at the three matters in section 17.

Your Honours will recall in Mutual Pools earlier

this year - it is reported only at this stage in

104 FLR 545 in the loose part - that in that case

the court stressed the point that there were three

alternative ways set out by section 17, and there

is a balance between those three. They are all

ways in which a person deals with his own goods in

a semi-final sort of way; he sells them, he treats

them as stock for sale by retail, or he uses them

himself. In my respectful submission, that very

parallelism makes it unlikely that one is talking

of someone else's goods. One cannot, of course,
sell someone else's goods. One cannot treat

someone else's goods as stock for sale by retail.

How, therefore, can one apply someone else's goods

to one's own use? By definition, it is that other

person's use.

The final submission is the one concerning

aids to manufacture and this is a submission which

requires going through a number of fairly complex

provisions in the Act. It assumes, for reasons

Your Honours will see, that Your Honours are

against me on application to "own use", because if

the goods are not applied to one's own use, this

area does not arise.

The starting point is item 113C in the First

Schedule to the Exemptions and Classifications Act.

It is as page 95,741 of the booklet - and

Your Honours see at page 95,741 the item is:

Kodak(3) 22 7/4/92

Goods (other than lubricants) applied by a

registered person to his own use as aids to

manufacture (as defined by regulations - So the goods have to be applied by the manufacturer

to his own use. I see that gender neutral drafting

has not yet seeped into this item. One then goes

to the regulations to see what an aid to

manufacture is and subregulation 4(1) contains the

definition and that appears at page 93,502 and that

defines "aids to manufacture" as "goods for use by"

Kodak "in the course of carrying on a business"

being - and then paragraph (d):

goods (other than those specified in paragraph

(a) or (b) ..... for use as specified in

paragraph (a).

And it is slightly convoluted, but it is capable of

explanation and rational meaning. What that means

is, in effect, you go to the subparagraphs of

paragraph (a), (i) to (xi), but ignore the preamble

and the relevant subparagraph is subparagraph (3).

So to come within (d) one must be goods for use in

any processing or treatment for the purpose of
bringing goods into the form or condition in which
they are to be marketed or used by the
manufacturer. So goods used in any processing or
treatment for the purpose of bringing those goods

into the form or condition in which they are to be

used et cetera are included in (d), but it is

"other than those specified in paragraph (a)" so it

is not "machinery, implements or apparatus". So,

what (d) picks up is where the goods themselves are

used in the way described in 3 although they are

not "machinery, implements or apparatus".

So the argument is - and this part I do not

understand to be controversial, but I may be

corrected on that, I do not understand it to be -

that exposed film is therefore goods, not being

"machinery, implements or apparatus", which is

used:

in any processing or treatment for the purpose

of bringing goods into ..... the form or

condition in which they are to be marketed or

used by the manufacturer -

That is, bringing them into the condition of being

a negative so that they can be used by the

manufacturer at the next stage. Now, thus far I

have been perhaps prolix, but I hope not too

controversial. The problem arises in relation to

paragraph (k), which appears on the following page,

93,504, and that is an exclusion - (a) to (d) are

inclusions; (e) to (p) are exclusions, just to make

Kodak(3) 23 7/4/92

it easier to follow the paragraph, or the

subregulation, and paragraph (k), the exclusion is:

(k) goods for use in connection with the manufacture for sale of goods, if the first-mentioned goods are to be sold to

the purchaser of the goods to be so

manufactured, -

So, the exposed film is goods for use in connection with the manufacture for sale of negatives, if the negatives are to be sold to the purchaser of the

negatives so to be manufactured. So, the argument

is, because the negatives are deemed to be sold to

the customer, that picks up this exclusion. The

exclusion is, it is goods for use in connection with the manufacture for sale of goods, because

those goods are to be sold to the purchaser. Now,

that involves treating the word "sold" as including

a deemed sale, and it is there, we say, that the

fallacy in the application of this paragraph

arises, because we say "sold" there means actually

sold, not subject to a deemed sale.

Your Honours will be aware, of course, of the provisions of the Acts Interpretation Act, in

relation to Acts and Regulations, and - - -

DEANE J: Mr Bennett, I am sorry, you have lost me along the

way. If we come to (k), the relevant goods are the

treated negatives, are they not?

MR BENNETT:  No, Your Honour.
DEANE J: Why?

MR BENNETT: 

The untreated negative; the exposed negative film before it is a negative.

DEANE J:  I thought that you were trying to use this to get
an exemption in respect of the treated negative.

MR BENNETT: 

I am sorry. If I could just go back a moment, Your Honour, to the earlier provision, because I

may have tied myself up on this.
DEANE J:  No, I am no doubt wrong, because it is a bit of a

maze, but - - -

MR BENNETT:  Your Honour, let me just go back a step. I

one goes back to 4(l)(iii), there is an exclusion

in relation to "aids to manufacture". We say the -

DEANE J: But your starting point is that you are assuming

that the treated exposed negative is goods which

otherwise attract sales tax and you are using this

to escape from that position.

Kodak(3) 24 7/4/92
MR BENNETT:  No. No, I am not Your Honour. What I am

submitting is that the exposed negative film,

before it is treated, is an aid to manufacture,

because it is used in the processing or treatment

for the purpose of bringing that exposed negative

film into the condition in which it is to be

marketed or used. Now, if one puts it that way,

the paragraph (k) has no application. If one

treats it the second way and says the negative is

used in the shining of the light through, so the

negative is used:

in any processing or treatment for the purpose

of bringing -

a print into -

the condition in which

it is -

to be marketed or used -

one then turns to (k) and what has to be sold to

come within that exclusion is the negative.

So the area in which the present argument

arises, the argument dealing with (k), is in the

second of the two ways I put it and I may not have

made this clear the first time through. If one

treats paragraph (iii) as referring to the negative

- what Your Honour has called the treated negative

- that is used:

in any processing or treatment for the purpose

of bringing -

prints -

into ..... the form or condition in which they

are to be marketed -

So it is within the primary exclusion, and then (k)

says "negatives" -

for use in connection with the manufacture for

sale -

of prints -

if the first-mentioned goods -

ie, the negatives -

are to be sold to the purchaser of the goods

to be so manufactured -

Kodak(3) 25 7/4/92

So the exclusion arises if the negative is to be sold to the person who buys the print.

DEANE J: That was what I thought I was suggesting to you.

MR BENNETT:  I am sorry, Your Honour, if I misunderstood. I

had perhaps tied myself up in the convolutions of

these provisions. The argument we make is that
that sale cannot include a deemed sale. The

negative is of course always the property of the
customer, of the owner of the negative, the owner

of the exposed film, and therefore it is not goods

to be sold to him. The argument for the

Commissioner is there is a deemed sale under the

Act, and that brings this in.

The argument to which I now turn in the final

matter with which I will be troubling Your Honour

is how the Interpretation Act applies to this

exercise. The Interpretation Act provision is set

out on page 9 of my submissions.

DAWSON J: Is this a negative argument merely to take it out

of the exemption? You would otherwise have to

bring it in, would you not?

MR BENNETT:  My argument is to bring it into the exemption.

DAWSON J: But from the other side, it would be merely a

negative argument.

MR BENNETT:  Yes, Your Honour. The other side's argument is

that paragraph (k) takes it out of "aids to

manufacture", and I am now dealing with that.

Your Honours, section 46 of the Acts Interpretation

Act is set out on the top of page 9 of my

submissions. Your Honours see it says that:

unless the contrary intention appears,

expressions used in any instrument -

which include the regulations -

shall have the same meanings as in the Act

conferring the power.

The regulations are made under Acts including

Assessment Act (No 1), and one then has to go to

section 17A which deems a sale in certain

circumstances. The phrase used, Your Honours see

in the first line of the main paragraph of 17A(l),

is:

the manufacturer of the goods shall, for the

purposes of this Act, be deemed to have sold

the goods.

Kodak(3) 26 7/4/92

Your Honours will recall - I will not take

Your Honours to it - that there were numerous

discussions on deeming provisions and what deeming provisions mean. This Court and other courts have

referred to that on many occasions. One of the

leading expositions is that of Mr Justice Windeyer

in Hunter Douglas v Perma Blinds, (1970)

122 CLR 49. There is a detailed discussion which I

will not take Your Honours to at pages 65 to 66 of

that report.

What is important about that discussion and

about the general discussions of deeming is that

there are two types of deeming. There is deeming

which is purely definitional. A deeming which is

purely definitional cannot of course deem any fact

to exist; it simply is a matter of defining a
term. It cannot be wrong. That is the sort of

deeming which is picked up by section 46 of the

Acts Interpretation Act, definitions in the

principal Act and deemings which are definitional

deemings.

But this is not a definitional deeming. This

is rather saying that something shall be deemed to

have occurred. It is a bit like the example given

in Penna Blinds of deeming a document filed with

the Registrar of Patents to have been filed on some

earlier date. That would not carry with it the

consequence that for all purposes, it was done on

the earlier date. It is simply a deeming effect

for limited purposes.

That type or deeming, we submit, is not picked

up by section 46 of the Acts Interpretation Act.

The point is really as simple as that. Indeed, one

would not expect it to be, because the whole point

of these provisions about aids to manufacture is

that something occurs where there is an actual

sale. The whole point of the exclusion in (k) is
where there is an actual sale. Where there is

merely a deemed sale, there is simply no reason for

applying the exclusion.

It is also significant, when Your Honours look

at (k) - and I need to take Your Honours back to it

for this purpose; it is 93504. If Your Honours go

to (k), Your Honours will see it is:

goods for use in connection with the
manufacture for sale of goods, if the

first-mentioned goods are to be sold -

and it is "manufacture for sale", it is looking
forward to a future sale. It is hardly likely that
it is looking forward to a future deemed sale.
Paragraph (k) is concerned with the time of
Kodak(3) 27 7/4/92

manufacture. It is concerned with goods which are

going to be sold. The fact that subsequently they

go through something which the Act deems to be sale

for some artificial purpose does not make them into

goods which are going to be sold or goods which are

in the manufacture for sale.

That is not a problem with the words "for

sale" because the goods there being described are
the print which is sold, but in relation to the
words "to be sold", it is referring to the
negatives and they simply cannot be treated as

goods which are "to be sold". They are not going

to be sold but they may turn out to be subject to a

transaction which is a deemed sale.

Those are our substantive submissions. should briefly now mention the amendment.

I

The

amendment arises in this way: If Your Honours hold

that questions 1 or 2 should be answered, "No", but

that the taxpayer loses because of question 3, and

it is also only going to arise if 4 or 5 is

answered, "No", because it means that we lose - it

only arises if we lose solely on question 3, or

perhaps question 6, what would flow would be that

there is something which is not the manufacture of

goods at common law within the ordinary meaning of

that word, it is something which is simply applying

some process to the customer's goods, but which is

deemed to be a manufacture followed by something
deemed to be a sale although it is not a sale.

So, one has a non-manufacture and a non-sale. When one strips that away as Mutual Pools requires

one to do to look at the rail tax, what is really

being done is to impose a tax on a process applied
by Kodak to a customer's goods at the customer's
request, the goods then being returned to the

customer. It is like servicing a washing machine, or upgrading it, or upgrading a computer to a new

grade by putting some card in it. There is a

service being done for the person in relation to
his own goods after those goods have been sold to

him and well after they have left the commercial arena outlined by the doctrine of excise between

production and distribution to the customer. I am
not going to argue the point obviously, but the
point is that that creates a non-excise. The rest

of the Sales Tax Act, of course, is the Excise Act,

as Mutual Pools lays down and, therefore,

section 55 applies. As I say, it only arises if

that is the point on which we lose, and the only

point on which we lose.

We have prepared amended notices of appeal.

There are three of them, but they are identical, so

I will not hand Your Honours the three identical

Kodak(3) 28 7/4/92

documents and clutter up Your Honours' records with

those, but they will be handed to officers of the

Court afterwards. I will simply give Your Honours

one set in proceedings number 136 and Your Honours

can take it that the others are identical.

If Your Honours grant leave it is our

intention, when Your Honours deliver judgment, if

the point then does appear to arise, and it will
not on most versions of the answers to the
questions, but if it does arise we will then ask

Your Honours to remit this issue to the Federal

Court.

What has occurred is, as I said at the very

beginning of my submissions, that unbeknownst to us

with some admirable foresight because it was before

Genex reserved this point in the Federal Court, to the validity of the provision in the Federal

Court. Because it is a stated case from the

Federal Court, if the taxpayers lose these proceedings, they can go back and argue this point

in the Federal Court and we simply want to be part
of all that. So we simply wish to hitch our wagon
to their horses in respect of this point which they
have taken and we only became aware of at the end
of last week. It will not involve the Court -
MASON CJ:  You are not expecting a grant of leave, even at

the best, until the Court delivers judgment on the

arguments that you have presented thus far.

MR BENNETT:  I am content with that, Your Honour. The only

slight problem arising out of that is - the only

thing that concerns me about that is the practical

problem that always arises in that judgment is

often taken on very short notice and taken by

people who are not familiar with the case, and it

may be necessary, if that is done, for someone to

ask for a short adjournment, which might be
inconvenient to the Court. I am only concerned

about the practicalities in relation to that.

MASON CJ: Yes.

MR BENNETT:  I would prefer, if Your Honours were prepared

to do it, for leave to be given at this stage, on
the condition, if one likes, that the point would

only be raised if it arises, and if it arises we

will remit it to the Federal Court so that that

court can hear it with the argument in Genex's case

in that court.

MASON CJ:  When would you intend to serve the 78B notice if

we gave leave to amend now?

Kodak(3) 29 7/4/92
MR BENNETT:  Your Honour, I think what we would do -

although it probably is not necessary - is serve a
notice now which explains the procedural step we

intend to take so that the Attorneys will realize

that there will be no need to intervene unless and

until the matter goes back to the Federal Court. I
would not anticipate that they would have any
interest in the procedural issue as to whether I
get leave or not.

Obviously there would have to be a notice before the hearing in the Federal Court of the

matter, and it would only be a matter of courtesy
which would dictate that we serve one now. I would

have thought the real one, if I may put it that

way, would be after the matter was remitted. In

fact, on thinking about it, there is probably

little reason, even courtesy, for telling the

Attorneys now. It may concern them with a matter

which will never arise and cause them

inconvenience. So we would envisage serving it,

Your Honour, when and if the matter was remitted to

the Federal Court. May it please the Court.
MASON CJ:  Thank you, Mr Bennett. Yes, Mr Gzell.

MR GZELL: If the Court pleases, first, might I simply say

we do not oppose -

MASON CJ:  Mr Gzell, it may be convenient to hear what

Mr Bloom has to say at this stage because we will

then get the totality of the argument from that

side and that may be of assistance to you.

MR GZELL:  If Your Honours please. Your Honour, before I

resume my seat, might I simply say we do not oppose

the application for leave to amend.

MASON CJ: Thank you. Yes, Mr Bloom.

MR BLOOM:  Can I hand up an outline of our submissions,

Your Honours.

MASON CJ:  Mr Bloom, I should say the Court will grant leave

to amend as requested by Mr Bennett.

MR BLOOM: 

If Your Honours please. Your Honours, we point out in the beginnic

that the businesses of the

respondents invol\: two things: the first is the

developing of the films, the customer's films; and

the second is the printing of photographs from

those developed films or the negatives as they have

been called, the prints being sold to the

customers.

In not all cases are the prints made. In some

cases, the sole service which the respondents

Kodak(3) 7/4/92

perform is to develop the films so as to produce

the negatives and those negatives are then returned
to the customers. The point of that distinction is

to remind Your Honours that the effect of the

decision of the Federal Court, if it be correct, is

that sales tax will be exigible in those cases. It

will not be exigible in respect of the negatives

where the negatives are used to perform the further
step of making the prints but it will, on what the

Federal Court has held, be exigible in those cases

where the negatives are returned without that

further use by the respondents.

We remind Your Honours of the sections

imposing sales tax, that is, of course, in the

Rating Act, section 3 of which is at page 92,423:

Sales tax is imposed, at the rates specified

in section 4, upon the sale value of goods

manufactured in Australia by a taxpayer

and ..... sold by the taxpayer or treated by the

taxpayer as stock for sale by retail or

applied to the taxpayer's own use.

Section 19 of the (No 1) Assessment Act defines the

taxpayer. It appears at page 92,273:

Sales tax shall be paid by the manufacturer of

goods manufactured in Australia and -

(a) sold by the manufacturer .....

(b) treated by the manufacturer as stock for

sale by retail; or

(c) applied by the manufacturer to his own

use.

And, of course, the same three taxing events are

referred to in section 17 which is the provision

usually cited as the provision levying the tax.

Your Honours have been taken to the definition

of "goods" and "manufacture" and I will not, at
this point take Your Honours to those further.

Section 17A was inserted for a particular purpose,

really to deal, it appears, with made-up suits,

where the customer supplied his own bolt of cloth.

Sir Owen Dixon, in Commissioner of Taxation v Jack

Zinader, 78 CLR 336, dealt with this purpose at pages 342 to 343. At the bottom of page 342:

Section 17 of the Act provides that sales tax
shall be levied and paid upon the sale value
of goods manufactured in Australia by a

taxpayer and sold by him. Section 17A imposes

upon a transaction by which one person

Kodak(3) 31 7/4/92

manufactures goods for another out of that

other's material the artificial character of a

sale. The section provides that where goods

are manufactured for a person wholly or in

part out of materials supplied by him the

manufacturer of the goods . . shall for the

purposes of the Act be deemed to have sold the
goods to the first-mentioned person, at the

time of their delivery to him for the amount

charged to him by the manufacturer in respect

of those goods.

The point of that, Your Honours, is that

section 17A is a general provision. It was not

inserted to deal specifically with the facts of

this case but was inserted, indeed, much earlier to

deal with the particular situation to which

Sir Owen Dixon refers and as, I think,

Mr Justice Hill also sets out in His Honour's

judgment in the Federal Court, if I might just take

a moment to find that. At appeal book 67,

commencing at the bottom bottom of that page,

His Honour said:

Section 17A, on its face has clear application to a class of case where the

customer supplies materials (eg cloth) to a

manufacturing tailor, who makes up goods from

that material and then delivers the finished

product (eg the suit) to the customer. The

manufacturing tailor is then deemed to have

sold the finished product to the customer. By

virtue of s.18(1B) of Assessment Act No 1,
introduced at the same time ass 17A, the sale
value will normally be the making-up fee

unless the materials themselves are exempt

from sales tax in whole or in part. The

finished suit is clearly made in whole or in

part out of the materials supplied (the cloth)

Now, the point is, Your Honours, that in the cases and is delivered in that form to the customer.

to which it is directed, section 17A will operate

without straining the word "goods" wherever

appearing in that section. It is only in this case

where the Commissioner calls section 17A in aid

that he asks for a strained construction of the

word "goods" in order to achieve the result he
wants. Ax he does so in the face, Your Honours,

of two pro,risions which were in the same amending

Act as introduced the definition of "manufacture"

to include the processing of film to form

negatives.

If Your Honours go back to the definition of

"Manufacture" on page 92,142, Your Honours recall

Kodak(3) 32 7/4/92

that that part of the definition with which this

case is concerned is paragraph (d):

the processing or treatment of exposed

photographic or ..... film to produce a

negative.

But paragraph (e) and (f) were also added by the

same Act. Paragraph (f) deals with:

the copying or reproduction of visual images

or sounds -

and in relation to those additional amendments, and

in particular paragraph (f), there were inserted

two more sections; sections which, in the case of

visual images and sounds, do the work which the

Commissioner wants the general provision,

section 17A, to do here. Section 3(3A) at

page 92,161 says this:

Where goods to which section 18B would apply -

these are goods embodying visual images or sounds -

if the goods were sold by a person to another

person are given by the first-mentioned

person -

like the negatives here -

then, for the purposes of this Act, the

first-mentioned person shall be deemed to have

sold the goods -

So there is a specific provision dealing with

visual images or sounds; 17A is not relied upon.

The next section is section 18B, which

specifically defines a sale value - that is at page

are embodied. There was no attempt in the same 92,264 - for goods in which visual images or sounds
statute - which incidentally was the statute which
inserted the provisions dealing with concrete
pools - to put in similar provisions to deal with
negatives and it is completely possible that the
legislature intended therefore that negatives were
to be treated as manufactured and to be treated as
goods - that is against us, but were to be treated
as goods, by that deemed manufacture process - and

that in those cases only where the negatives were redelivered to the customer as such without first

having been used to make a print, there would be
sales tax exigible and that is supported, with
respect, by the fact there were no provisions
similar to 3(3A) and 18B to deal with negatives.
Kodak(3) 33 7/4/92

Your Honours, I have digressed a little from

our outline of submissions, but I do so to take
account of the fact that Your Honours have already

heard a little about this matter from my learned

friend, Mr Bennett.

Our submissions are set out in paragraph 6 in

summary form at page 3. We say, and both courts

below have accepted this, there was no

"manufacture" within the ordinary meaning of that

word. We put secondly, but obviously not as

strongly, that notwithstanding that, in terms, the

definition of "manufacture" is satisfied, that is

the amended definition, there were no "goods

manufactured". Alternatively, we say, that_ if on

either construction there were "goods

manufactured", no taxing point ever arose in

respect of such "goods", because they were not
applied by the manufacturer to his own use, because

they were not his goods and they were not sold by

him and they were not deemed by section 17A to be

sold because, at the point at which they were

delivered to the customer, they were no longer

goods within the definition.

Your Honours, as to the first of those points, there is no manufacture within the ordinary

meaning, it is clear from the cases that what is

required for there to be "manufacture", in the

ordinary sense of that word, is that new and

different goods emerge, and that is the test which

the courts have said, in both England and

Australia, is the test to see whether there has

been "manufacture". McNicol v Pinch is where it

first appears; in Jack Zinader, Sir Owen Dixon, at

the pages indicated, said that that is the test to

be applied here.

In Jax Tyres, the question arose as to whether

the substantial processes involved in turning a

worthless tyre into a retread, which had a

distinctive commercial market and which was used by

many people in place of brand new tyres, whether

that substantial process was "manufacture" for

sales tax purposes, and the Full Federal Court held

that it was not, because you started with a tyre

and you ended up with a tyre; you did not get new

and different goods in the sense which the cases

require.

Your Honours, there is a passage in

Totalisator Administration Board, 170 CLR 508, the

passage at page 511, where Your Honours remind us

at about point 3:

However, it has long been accepted that the

expression "goods manufactured in Australia",

Kodak(3) 7/4/92

even with the aid of the definitions contained in section 3(1) of the Act, does not extend to

every object transformed or brought into

existence by a physical process or operation.

BRENNAN J: Is function a test of newness?

MR BLOOM: 

Not of itself, Your Honour; it is one of the things that one looks to, certainly.

Change in

character; change in utility; one looks at all

those things, but the retreaded tyre, for

instance - and Your Honour knows that on aircraft

tyres are retreaded some 15 times, or at least if

Your Honour was in that case Your Honour would know

that - those are not new goods. There is obviously

a difference in utility; difference in function.

One cannot use the tyre before it has been

retreaded, except for a swing in the backyard or

some similar purpose, but as a useful item as a

useful tyre it must have this process of retreading

applied to it, but because one starts with a tyre

and ends up with a tyre, the cases held that that

is not "manufacture".

And it was the same with the saccharin. The

two saccharins had different markets; the one which

was in question, that had been produced from the

earlier saccharin, was far sweeter, far stronger;

it had a definite different market, but it was held

that none the less, that was not the manufacture of goods for the purpose of legislation concerned with the concept of manufacture.

BRENNAN J: That does indicate, does it not, that mere

physical substance, though carried from one stage

to another, is not necessarily inclusive of the

identity of the thing manufactured?

MR BLOOM:  Yes, Your Honour.
BRENNAN J: Well, in this case we have got the film exposed

before something is done to it. At that stage it

is incapable of producing a print. Afterwards, we

have got something which is capable of producing a

print with an alteration in the chemical substance

of that film. Is that sufficient to make it new
goods?
MR BLOOM:  We say no, Your Honour.
BRENNAN J:  Why not?
MR BLOOM:  I think that the way it was best put was by
Mr Justice Mahoney in the Court of Appeal. It is

set out in this appeal book in the judgment of

Mr Justice Hill, if I might just find that passage

because it really puts it very aptly, with respect,

Kodak(3) 35 7/4/92

and better than I could. In the Kodak appeal book,

my learned friend Mr Gzelle says it appears at

page 91, and in Genex at page 55, about line 17:

The description of the goods when purchased

was "photographic film"; it was not, I think,

"unexposed photographic film". The goods

remain, I think, photographic film, whether

they be unexposed, exposed, or so treated that

the chemicals upon them disclose in negative

form the images to which they were

exposed ... ".

It remains the same goods, Your Honour, and if that

is right, then there is no manufacture.

DAWSON J: It remains the same piece of actual physical

film, does it?

MR BLOOM: It remains exactly the same film. All that has

happened is that it has passed through a process

and, Your Honours - - -

DAWSON J: Yes, and when you get the bits that are snipped

up, those are bits of the film which you bought?

MR BLOOM:  Yes, Your Honour, just gone through that process.

Your Honour, the definition of "manufacture", if I could take Your Honours back to that at 92,142,

does include certain combinations and certain

treatments specifically in it but not this sort of

treatment. For instance, a treatment applied to

food stuffs as a process in the preparation of food

stuffs for human consumption is defined as
manufacture, and one presumes that without that it

would not be, and this sort of treatment would not ordinarily be manufacture, and is not specifically

defined as such until one gets to paragraph (d)

in 1986, and there is a reason for the specific

need to so define it, in our respectful submission.

Your Honours, there is clearly "manufacture"

within the extended definition, that is within

paragraph (d), but as my learned friend,

Mr Bennett, pointed out, the legislature has not taken the further step of deeming the product of

that manufacture to be goods. The definition of
"goods" does not include it. There is no

manufacture according to ordinary concepts, and so

there does appear, if my learned friend's

submission is right on that point, to be a

misfiring totally of the legislation.

There was a not dissimilar situation, different in one respect which I will come to,

involved in Commissioner of Taxation v Comber, a

decision of the Full Federal Court, the only report

Kodak(3) 36 7/4/92

for which we have in 17 Australasian Tax Reports

413. That was a case involving section 109 of the

Income Tax Assessment Act. That section says that

certain overpayments of salaries by a company to

directors shall be deemed to the extent of the

overpayment to be a dividend.

So section 109 deemed it to be a dividend. Section 44 of the Tax Act, however, says that the

only person who can be taxed on a dividend is a

shareholder. The particular director who received
the overpayment was not in fact a shareholder. The

Commissioner argued that notwithstanding, because

the amount was deemed to be a dividend, and

dividends can only be paid to shareholders, he

should be assessable on it as having received a

dividend and as being deemed to be a shareholder.

The Federal Court refused to accept that. It

said it was paid to him, he was not in fact a

shareholder. Section 44 of the Tax Act requires

the recipient to be a shareholder, therefore he was

not assessable. But it is true that they could

come to that conclusion in the light of a provision

which deemed it to be a dividend paid by the

company and so had an effect for the purposes of the company's assessment. The company would not get a deduction for an amount of such an

overpayment, but the amount would be a dividend

that would be taken into account for the purpose of

what was then undistributed profits tax.

At page 420 in the judgment of

Mr Justice Fisher, at the top of the page:

I find the Commissioner's construction

unacceptable. In my opinion deeming
provisions are required by their nature to be

construed strictly and only for the purpose

for which they are resorted to. It is

improper in my view to extend by implication

the express application of such a statutory

fiction. It is even more improper so to do if

such an extension is unnecessary, the express

provision being capable by itself of sensible

and rational application.

Here we do not have that rider. Here, if

Your Honours accept the submission that

notwithstanding the deemed definition of

"manufacture", there are no goods, the legislation

misfires in its entirety. It is no doubt that

reason which led the Federal Court to conclude that

the legislature must have intended that what would

be the product of deemed manufacture should be

deemed also to be goods, notwithstanding the

absence of a specific provision. But it remains
Kodak(3) 37 7/4/92

the case, and we stress that point, that there is

no provision deeming these to be goods.

McHUGH J: 

What do you say about what Lord Diplock once said in an extra-judicial speech that if courts can

identify the target of legislation, their duty is
to ensure that it is hit, not to record that it has
been missed?
MR BLOOM:  I could not say a lot in contradiction to that,

Your Honour, especially not when Lord Diplock says

it. It is no doubt precisely what led the Federal

Court to hold here that the negatives should be

treated as goods as the product of that which was

defined as manufacture. I do not say much in

strong opposition to that, Your Honour.

BRENNAN J: What is the subject that is deemed to be

manufactured, or is ''manufacture" a concept which

exists in vacuo?

MR BLOOM:  If one goes back to the definition, Your Honour,

it is perhaps by use of the words in the definition

of manufacture:

the processing or treatment of exposed

photographic or cinematographic film to

produce a negative -

Presumably that which is produced, the negative, is

intended on that construction to be goods. But it

is not defined as such, but none the less may be

because why else would the legislature define it as

manufacture if that were the result. I know it is

against us to put it that way, Your Honour. Your Honours, if the negatives are goods, it

then becomes necessary to determine whether a taxing point arises and, as my learned friend

Mr Bennett pointed out, there are two possible
taxing points. One is application to own use and
the other is deemed sale under section 17A. They
are the only two possibilities.

Your Honours, we have given Your Honours a reference to York Motors to remind Your Honours

of the Rating Act and sections 17 and 19 of the

that the three taxing events specified in section 3 predicated of a manufacturer, of a taxpayer, that

he may do all of the three things. That is, he may sell the goods by wholesale or he may apply them to his own use or he may treat them as goods which he

will sell by retail. And at least two of those can
only be done by the owner because he is the only
one who could sell them by wholesale or by retail
and we say that since all three of those things are
Kodak(3) 38 7/4/92

intended to be something that that one person can

do, application to own use likewise can apply only

to the owner. The question which Your Honours

passed over in State Bank could only be answered,

with respect, in that manner, now that it arises

here.

We have given Your Honours a reference to a

passage in the judgment of Lord Green in Morris v

Lunzer. His Honour was there dealing with the

English purchase tax and identified the equivalent to application to own use in that English

legislation as really an alternative to sales,

selecting a point of time comparable to delivery in

the case of a sale. Again, the concept is that one

may sell them or apply them to one's own use, but

can do either.

It was Mr Justice Dixon, at the page we have

referred Your Honours to at the top of page 5 in York Motors who first said, before this Court in State Bank, that those three events are true

alternatives.

Your Honours, negatives have only one use. It

is clear from the appeal book, page 23, paragraph

44, that they can only be used to produce prints.

That is their only use. That is part of the stated

case. It is accepted. The question is, though,

can that involve an application to own use. We
say, no, we are not the owner. We may be the

manufacturer of the goods and the manufacturer of
the prints, but in using those negatives, which at

all times, it is accepted, remain the customer's

goods, we are not applying them to our own use

because we do not own them.

Your Honours, the cases dealing with

application to own use, two of which my learned

friend Mr Bennett referred to - Taubmans and Max

Factor - express it in those terms. In Taubmans, 115 CLR 570 - - -

DAWSON J: If I applied the negatives to make prints for my

own purposes, would I be applying them for my own

use?

MR BLOOM: 

If you were the customer and you owned them, Your Honour, yes, but Your Honour is not a

manufacturer and there is no sales tax.

DAWSON J: Well, who owns the prints before they are given

to the customer?

MR BLOOM:  The prints are owned by the manufacturer and he
sells them, but the negative never is. The
developer; the photographic laboratory. The
Kodak(3) 39 7/4/92

negative, however, remains at all times the

property of the customer.

DAWSON J:  Why can he not apply it for his own use in making

prints?

MR BLOOM: 

He can, but that does not have any effect for taxing purposes.

The question is whether, when the

photographic laboratory uses the customer's

negative to make prints, the photographic

laboratory can be said to be applying goods not its

own to its own use.

DAWSON J: Yes, well, why can it not?

MR BLOOM:  Because it does not own them.

DAWSON J: It does not matter. If you lend me your

negatives and I apply them to make some prints for

myself, I am applying the prints for my own use, am

I not?

MR BLOOM: 

It depends on what application to own use means and the significance of the word "own",

Your Honour.  I can see what Your Honour says,
but - - -
DAWSON J:  By if I use something for me, I am applying it

for my own use, am I not?

MR BLOOM:  If I give you the negatives and ask you to make

the prints for me, I may, with respect,

Your Honour, be asking you to apply them to my use.

The question is, what is the significance - - -

DAWSON J: 

What I am saying is, the prints are not the customer's until he pays over the money for them.

MR BLOOM:  But the negatives are. I accept what Your Honour

says.

DAWSON J: That is a different thing.

MR BLOOM:  No, and may I say why, Your Honour, because I am
obviously not making it clear. Our submission is

this, that because of the fact that those three

taxing events are true alternatives, application to

own use, sale by wholesale, sale by retail, that

those events are events, all of which can be done

by the manufacturer, the taxpayer. Now, sale can

only be done by the owner, and given that one

construes the sales tax legislation as a whole in

this manner, what one is targeting in section 17

and section 19 and in the Rating Act is acts by the

owner of the goods which are being applied to own

use. Now, if that is right it matters not that one
Kodak(3) 40 7/4/92

could in ordinary parlance say that they are being

applied also to use of others.

DAWSON J:  I understand what you are saying and I accept

that that is the argument. All I was suggesting to

you is it is perfectly clear when goods are

consumables. I mean, if the manufacturer of beer

drinks some of his beer, he is applying it to his

own use and there is no further use to which it can

be put. Where you have something like a negative

which can be used to manufacture a further article

and that article is, at the time it is
manufactured, that of the developer, until it is

sold it is a slightly different situation.

MR BLOOM: There are difficulties, of course, with this

particular piece of property. The print is not the
laboratory's for sale to anyone it pleases. The

print can only be sold back to the owner of the

negatives because of copyright or, alternatively,

sold to others with the permission of that person.

It is a particular sort of property. But what we

are really saying, Your Honour, is this, that
because of the way the sales tax legislation is

constructed, application to own use means

application by the owner of the goods about whom

the question arises, have those goods been applied
to own use, and here that is the negatives and they

are not owned by the photographic laboratory and,

therefore, for the sales tax legislation purposes

the taxing event, or the taxing point, has not been

passed.

Your Honours, in Taubmans, 115 CLR 570,

Mr Justice Windeyer, at 573 to 574, posed the

question in the second-last paragraph:

The question then is simply: did the

defendant apply the goods to its own use

within the meaning of the Act? The argument

that it did not is based largely on the notion

purpose of their being then by them given that they were given away to retailers for the away. In one sense that is so. But that does

not conclude the question.

And then, the next paragraph:

Whether or not a thing is used by its

owner or applied by him for his own use -

so His Honour Mr Justice Windeyer felt it necessary

to add in the word "owner" there in the context of

the sales tax legislation -

he being a person conducting a business

depends, it seems to me, upon the use to which

that kind of thing is put in that kind of

business. The idea connoted by the phrase
Kodak(3) 41 7/4/92

"applied by him for his own use" is not

inconsistent with a gratuitous disposal of the

thing by its owner. The nature of the use to

which the thing is designed to be put is a

most material consideration.

And in Max Factor in the judgment of

Sir Harry Gibbs at page 361, about point 5 of the page:

On behalf of the appellant it is

submitted that the goods which it gave away

were not applied for its own use within
s. 17(1). The goods were given by the
appellant with a view to achieving and
maintaining a satisfactory volume of sales of
cosmetics, and thus for the appellant's own

purposes, but it is submitted that this is not

enough. It is said that the words "to his own

use" ins. 17(1) are not equivalent to "for

his own benefit" or "for his own purposes" but
refer to the physical use of consumption of

the goods by the person on whom the tax is

imposed. In other words, the submission on

behalf of the appellant is that goods

manufactured by the appellant would be applied

to its own use withins. 17(1) only if the

appellant physically used the goods itself,

and that if the appellant gave the goods away

to someone who did not receive them as its

servant or agent it cannot be held to have
applied them to its own use, notwithstanding
that they were given for the purposes of the

appellant and that the transaction was

beneficial to the appellant.

I cannot accept this submission. The

meaning of the noun "use" is not confined to

physical consumption.

So, Your Honours, we say there was no application

to own use for the simple reason that the negatives

did not belong to the respondents at the time at

which - -

TOOHEY J: Is that the only reason, Mr Bloom? Is it vital

to your argument about application to own use that

the goods were not owned by the taxpayer?

MR BLOOM:  Yes. Your Honour. We say that application to own

use in the sales tax legislation can only refer to the owner of those goods, and not only section 17,

not only section 3 of the Rating Tax, but very

clearly section 19 of the Assessment Act in

identifying the taxpayer makes that clear. And may

I also remind Your Honour of section 18(3) which

supports this construction. That is the section -

Kodak(3) 42 7/4/92

it appears at page 92,251 - that gives a sale value

in the case of goods applied by the manufacturer to
his own use and it supports, with respect, the
construction for which we contend, namely that the

person there referred to is the owner of the goods:

For the purposes of this Act, the sale

value of goods manufactured by any person and

applied to his own use shall be the amount for

which those goods could reasonably be expected

to be sold by the manufacturer -

So he has got to be the person who would be able to

sell those goods, that is pass title in them.

Your Honours, Sir Owen Dixon, in all the sales tax cases - Ellis & Clark, Davies Coop - always

said that one must read section 17 and 17A, with

the sale value provisions in section 18 to get a

proper understanding of the sales tax scheme.

And in further answer to Your Honour

Justice Toohey, we do say that we use them and, if

they were our own goods, we would be applying them

to our own use, and that is a fundamental part of

our argument as well, but they are not our own

goods, therefore we do not apply them within the

meaning of that term in the legislation.

TOOHEY J: Yes, I understand that.

MR BLOOM:  Your Honours, we then pass to section 17A. I

have already taken Your Honours to what

Sir Owen Dixon said in Jack Zinader on section 17A as to the purpose of that section and to the

passages in the judgment of Mr Justice Hill in the
court below at pages 67 and following, but if I may
take Your Honours back to page 68 in the appeal
book, where His Honour deals with the argument

here. In the middle of page 68:

When one seeks to apply section 17A to

the present facts there are two difficulties.

The first may readily be overcome. There is

some oddity of language in describing the

negatives as having been manufactured (reading

"manufacture" in its defined sense as

including the processing or treatment of

exposed photographic film to produce a

negative) out of the materials supplied by the

customer -

Section 17A contains those words. It may assist if

Your Honours were to have on the left-hand side

section 17A at the same time as one is reading what

His Honour says at page 68 and following. So the

first problem, His Honour says, can readily be

Kodak(3) 43 7/4/92

overcome, because mere oddity of language ought not

to stop one from concluding that the exposed films
are, in effect, materials supplied by the customer,

out of which the negative is manufactured goods.

This is the last paragraph on page 68:

For the applicants it was submitted that at

the at which s 17A spoke, that is to say at

the time of delivery of the negatives to the

customer, the negatives, assuming them to have

been "goods" at all, had ceased so to be by

virtue of the fact that as negatives they had

gone into use and consumption in Australia, ie

that they had been, by then, used in the
printing process. For the Commissioner, on
the other hand, it was submitted that as a
matter of construction it was unnecessary that
the negatives be goods at the point of
delivery, but even if it were necessary, the
negatives were not used in the printing

process, that process merely amounting to

shining light through them. This last

submission, which involves an over simplistic

view of the process of making prints, and

results in there being no real use at all of

negatives, may be immediately rejected -

particularly in the face, Your Honours recall, of

the stated fact that the only use for negatives is

to make prints.

If I might just interpolate there for a

moment, "use" is a word of very wide definition.

This Court in Stewart's case, 154 CLR 385,

indicated that "use" was a word of very wide

connotation in the context of the sales tax

legislation, as elsewhere. At page 391, the middle

of the page, in the judgment of Sir Harry Gibbs:

The starting point of the argument

presented on behalf of the Deputy Commissioner

is that the machines were applied by the

respondents to their own use, and therefore

liable to tax under ss 17 and 19 unless

exempted by the Sales Tax (Exemptions and

Classifications) Act. The next step in the

argument is that the application of the

machines to the use of the respondents

occurred when they were manufactured, and
before they were supplied to the public
benevolent institutions. It followed, so it

was submitted, that as soon as the machine had

been manufactured it had "gone into use" in

Australia within the meaning of those words in

the definition of "goods", and had therefore
ceased to be "goods" as defined ..... and did

not fall within the

Kodak(3) 44 7/4/92

exemption ..... Alternatively, it was submitted

that ss 17 and 19 provide three "taxing
points", one of which is the application of
the goods to the use of the manufacturer, and
that it is at the time when the goods pass the

taxing point that it is necessary to inquire

whether they are covered by -

the exemption. That was a submission by the

Commissioner that the goods having been applied to

own use by the unquestioned manufacturer and owner

of them in that case, they had, also, therefore,

gone into use. And having therefore gone into use,

they were no longer goods at that point in time,

having regard specifically of the definition of

"goods" and its exclusion of goods which, by a

process of retailing or otherwise, have gone into

use or consumption.

At page 393, at about the middle of the page,

after the reference to York Motors:

The Court was there discussing the meaning of

of "treated" ins 17, and not the meaning of "applied", and it was not concerned with the effect of the Sales Tax (Exemptions and

Classifications) Act, or with the meaning of the words "gone into use" in the definition of

"goods". The word "applied" means "devoted

to" or "employed for the special purpose of"

(Max Factor & Co Inc v Federal Commissioner of

Taxation) and although in some cases goods may no doubt be applied to the use of a person simply by keeping them in reserve - eg by

keeping spare parts for use in the person's
vehicles or machinery - in the circumstances
of the present case the application of the
machines to the use of the respondents
occurred when they were devoted to the

respondents' purposes by supplying them to the

institutions. In other words, the respondents

did not apply the machines to their own use,

and the machines did not go into use, when

they were made and kept ready for subsequent

delivery to one of the institutions.

The point of that, Your Honours, is this, that

there is a connection drawn there between the

concept of application to "own use" which, in our

submission, of course, is something which only the

owner can do, and the goods at that same point in

time going into use in Australia so as to cease

being, for sales tax purposes, goods.

Of course, we say that when one gets to section 17A, at the point of delivery, they have

been used to print photographs, that being their

Kodak(3) 7/4/92

only use, they have therefore gone into use, they

are therefore not goods, and section 17A cannot be

strained to achieve that result. Your Honour

Justice Brennan was to the same effect at page 396

in that case.

Your Honours, we have referred to the relevant principles of statutory construction.

They have

recently been gathered in the judgment of

Justice McHugh in Hepples' case. The only report

for that we have is 65 ALJR 650, and the passage

commences at pages 667 to 668, under a reference to

a section which one is perhaps grateful is not

involved in these proceedings. Your Honour
Justice McHugh said: 

In Attorney-General for Canada v Hallet &

Carey Ltd, Lord Radcliffe pointed out that

"the paramount rule remains that every statute

is to be expounded according to its manifest
or expressed intention". In determining that

intention a court "must give effect to what

the words of the statute would be reasonably

understood to mean by those whose conduct it

regulates" -

I would pause there to remind Your Honours that we

are concerning the general provisions of section

17A, which the Commissioner wants strained to deal

with this particular case; not generally, but to

deal with this particular case.

Black-Clawson Ltd v Papierwerke, per

Lord Diplock, at 638. These statements do not

mean, however, that the intention of

Parliament is commensurate with the ordinary

grammatical meaning of the legislative

provision in question. As I pointed out in

Corporate Affairs Commission of New South

Wales v Yuill, the literal or grammatical

meaning of a legislative provision is not always the meaning which Parliament intended
the enactment to have. Thus, Parliament is
presumed to have intended that the meaning of
its enactment should be determined by applying

the rules of construction which traditionally the courts have used to construe legislation.

The application of those rules often results in the "intended" or statutory meaning being

different from the literal or grammatical
meaning of the enactment. As
Mason and Wilson JJ pointed out in Cooper
Brookes (Wollongong) Pty Ltd v Federal
Commissioner of Taxation:

"The fundamental object of statutory

construction in every case is to

Kodak(3) 46 7/4/92

ascertain the legislative intention by

reference to the language of the

instrument viewed as a whole.

That means here, section 17A, viewed in the light

of the definition in section 3, and one is asking

vis-a-vis 17A, is there a context which requires a

different construction of the word, is there a
context in 17A that requires a different

construction?

But in performing that task the courts look to

the operation of the statute according to its

terms and to legitimate aids to construction.

The rules (of construction), as

D. C. Pearce says ..... are no more than rules

of common sense, designed to achieve this

object. They are not rules of law. Departure

from the literal or grammatical meaning of a

legislative provision "extends to any

situation in which for good reason the

operation of the statute on a literal reading

does not conform to the legislative intent as

ascertained from the provisions of the

statute, including the policy which may be

discerned from those provisions".

Now, pausing there for a moment, that may well

apply to the situation where we have a deemed

process of manufacture, but no deemed goods and we see the force of that argument, but in the case of

section 17A which on its ordinary interpretation, as it was inserted, is perfectly fit to deal with the situation for which it was inserted - there is

no call, with respect, to depart from those words

and the definitions of terms used in that section

merely to accommodate the peculiar factual

situation with which the Commissioner finds himself
here, particularly in the light of the fact that

the same piece of amending legislation contained

equivalence of what the Commissioner is asking this provisions to deal with visual sounds that were the Court to do here with section 17A. Your Honours, I
see it is a quarter to one.

MASON CJ: Yes. We will adjourn until 2.15, Mr Bloom.

AT 12.45 PM LUNCHEON ADJOURNMENT

Kodak(3) 47 7/4/92
UPON RESUMING AT 2.17 PM: 
MASON CJ: Yes, Mr Bloom. 
MR BLOOM:  If Your Honours please. Your Honours,

immediately before the luncheon adjournment I had

arrived at paragraph 16 of our outline. If I may

just summarize where we are at that point in

relation to this issue. First we are assuming

against ourselves, indeed as the Federal Court held

and as Lord Diplock would hold, that the

legislation ought not to be stultified and that

negatives are goods which are manufactured, because

the processing or development is defined as

"manufacture". But now the Commissioner wants to
go one step further. He wants to say that

notwithstanding that in most cases the negatives

are used to print photographs, none the less they

should be treated as still being goods for the

purposes of section 17A. So that, not only in
those cases, as the Federal Court held, where the

negatives are produced and then redelivered to the

customer should sales tax be exigible on the value

of the negatives, but he wants to say that in all

cases, including those where the negatives are used

to print photographs and redelivered with the

prints, and that he says comes about because of

section 17A. And what he asks the court to do

there is to interpret section 17A in such a way

that the word "goods", at least in one part of it,

namely where it crosses the taxing point, does not

bear its ordinary meaning, that is, as defined by

section 3.

Now Your Honours, our answers are these:

firstly, one is construing section 17A as a general
provision, not as a provision enacted specifically

to deal with the facts of this case; secondly,

section 17A is perfectly capable of being given an

interpretation on the ordinary and grammatical

basis which will achieve the purpose for which it,

that is section 17A, was enacted; thirdly, it

should not be given a strained interpretation just

to accommodate the Commissioner's case here; and

fourthly, that is especially so where, on the

Federal Court's interpretation, the 1986 amendments

will have operation, that is in those cases where

the negatives are redelivered without being used to

make prints, and secondly where, in those same 1986

amendments, there were specific provisions inserted

in relation to other matters, the definition of

"manufacture" in paragraph (f) dealing with the

embodying of:

visual images or sounds -

Kodak(3) 48 7/4/92

and the like, and there were specific provisions in

subsection (3A) and section 18(3B), inserted to do

the very thing which the Commissioner wants from

section 17A here.

Your Honours, if I could take you back to

Justice McHugh's judgment in Hepples' case,

65 ALJR, where at the last paragraph on page 668:

Unless the context of a legislative provision or the purpose of the statute or the

application of a rule of construction throws

real doubt on the literal or grammatical

meaning of the provision -

here, section 17A -

that meaning must be taken as representing

Parliament's intention as to the meaning of

the provision. A court is not entitled to

depart from the literal or grammatical meaning

of a provision simply because that meaning

produces anomalies or inconveniences. Of

course, if the literal or grammatical meaning
gives rise to an injustice, or even in some

cases to an anomaly or inconvenience, it may

indicate that Parliament did not intend that

meaning to prevail. In Cooper Brookes,

Mason and Wilson JJ pointed out:

"Quite obviously questions of degree

arise. If the choice is between two strongly

competing interpretations, as we have said,

the advantage may lie with that which produces

the fairer and more convenient operation so

long as it conforms to the legislative

intention. If, however, one interpretation

has a powerful advantage in ordinary meaning

and grammatical sense, it will only be

displaced if its operation is perceived to be That is again the operation of section 17A.

unintended."

Your Honours, in paragraph 16 of our outline,

after the reference to Justice McHugh's judgment in

Hepples, we repeat this: given its natural

meaning, the section will bring to tax transactions not previously, that is before the 1986 amendments, taxable. In those circumstances, it would be

inappropriate to extend the words of the section

where the legislature itself has not chosen to do

so. We refer Your Honours to Lord Simonds' speech
in Wolfson's case, (1949) 1 All ER 865. The

passage is at page 868, two lines under the

letter B:

Kodak(3) 49 7/4/92

It was urged that the construction that I

favour leaves an easy loophole through which

the evasive taxpayer may find escape. That

may be so, but I will repeat what has been

said before. It is not the function of a

court of law to give to words a strained and

unnatural meaning because only thus will a

taxing section apply to a transaction which,

had the legislature thought of it, would have

been covered by appropriate words. It is the

duty of the court to give to the words of this
sub-section their reasonable meaning, and I

must decline on any ground of policy to give

to them a meaning which, with all respect to
the dissentient Lord Justice, I regard as

little short of extravagant. It cannot even

be urged that, unless this meaning is given to

the sub-section, it can have no operation. On

the contrary, given its natural meaning it

will bring within the area of taxation a

number of cases in which by a familiar device

tax had formerly been avoided.

And that, Your Honours, is this case based on what

the Federal Court has held. We have given

Your Honours a reference to two cases, firstly a

judgment of Chief Justice Gleeson in Bryan's case

and secondly a judgment of this Court in Bolton. It

is probably better that I leave those to reply

because they really deal with the use that we

anticipate our learned friends will make of the
explanatory memoranda and to this point, at least in

this case, there has been no use sought to be made

of those explanatory memoranda at all.

Your Honours, if we are wrong in our argument

that the negatives are not applied to our own use

because we do not own them and, if contrary to

that, they are applied to our own use, then it is

our submission that they are exempt as aids to

manufacture and, if Your Honours will forgive me

for taking Your Honours through it again, I might

just retrace the steps which Your Honour

Justice Deane and my learned friend Mr Bennett took

this morning, on the definition of aids to

manufacture. The interpretation is, we perceive,

that which Your Honour Justice Deane put to my

learned friend during the course of argument.

The relevant items are at page 95,741 and are

items 113B and c. Both of those apply to the

respondents in the second appeal. The first item picks up the definition as aids to manufacture in the Exemptions and Classifications Act and the

second, 113C, picks up the definition in the

regulations. But, as Mr Justice Hill said below,

Kodak(3) 50 7/4/92

there is no real distinction, for present purposes,

between those two definitions.

If one then goes to the regulations: regulation 4 appears at 93,502, and if one goes

first to paragraph (d) on 93,503, aids to

manufacture will be "goods (other than those"

excluded relevantly by paragraph (k) "for use as

specified in paragraph (a). One goes back to

paragraph (a) and ignores the words "machinery,

implements and apparatus" and inserts instead
"goods" by virtue of paragraph (d) and those goods

are, of course, the negatives. And then one reads it, with respect, we think this way: goods for use

by a registered person in the course of carrying on

a business, being negatives, "for use exclusively

or primarily and principally", down to (iii):

in any processing or treatment for the purpose

of bringing goods -

prints -

into the form or condition in which they are

to be marketed or used by the manufacturer of

the goods -

that is the prints.

Now, there is no argument, it would see, and

that may be because of the complexity of the

section, that if there is application to "own use",

the respondents come within those opening

paragraphs. The sole question is whether they are

excluded by subparagraph (k). Reading

subparagraph (k), if I may take the liberty of

doing it in the same way, it reads negatives:

for use in connection with the manufacturer
for sale of -

prints -

if the first-mentioned goods -

the negatives -

are to be sold to the purchaser of the -

prints. Now, the question is, can you postulate of

the negatives that they are to be sold to the
purchaser of the prints? The Commissioner's case
at no stage suggests that they are to be sold or
that they are, in fact, sold. His case is that

they will, by the happening of certain events which

fall within section 17A, be deemed to have been

sold once those events take place, and it is our

Kodak(3) 51 7/4/92

respectful submission that one cannot interpret the

words "are to be sold" as if they read "are to be

dealt with in such in a way that when they have

been so dealt with they will be deemed to have been

sold", and so, we say, that subparagraph (k) does

not apply, and we gain, with respect, some

assistance from (k)(ii) which anticipates that the

purchaser of those goods in the future sale may be

able to quote his certificate. Of course, there

can be no quotation of certificate in the deemed

sale situation, and so that subsection or

subparagraph cannot, in our submission, be speaking

of a deemed sale.

Your Honours, there is one last matter which

is not in our outline of submissions, but

Your Honours will have seen that Mr Justice Hill at

page 71 of the appeal book raised a matter which

had not been argued below. He suggested, at about

line 10 of page 71, that a way for the Commissioner

to get around all this might be to treat as the

sale value of the prints the amount charged for

development and printing.

Your Honours, as His Honour expressly says,

that matter was not the subject of argument in the

Federal Court and was not the subject of any

statement of fact in the stated case or any other

evidence. It would depend very much upon the

contract between the parties and the sort of matter

that was the subject of this Court's decision in

Commonwealth Quarries, the case mentioned at the top of page 71 by His Honour Mr Justice Hill and,

with respect, it not having been argued it would be

inappropriate, in our respectful submission, for

the-court to pass anything in relation to it. If

the Court pleases.

MASON CJ: Thank you, Mr Bloom. Yes, Mr Gzell.

MR GZELL:  If the Court pleases. I think our written

outline is with Your Honours.

MASON CJ: Yes, Mr Gzell.

MR GZELL: If the Court pleases, there are, as we have

discerned them, four planks to the arguments that

our learned friends have advanced. First, they

submit that developing negatives is not manufacture

according to ordinary concepts. The answer to that
proposition which our case develops is that,
according to ordinary concepts, the production of

the negatives is manufacture.

The second plank to their argument is that one

can have manufacture without producing goods and

our case is that there is a fundamental correlation

Kodak(3) 52 7/4/92

between manufacture and goods in the sales tax

legislation; that the legislation as a scheme

proceeds upon the basis that goods are the output

of manufacture. So that if one has a definition

which extends the concept of manufacture, the

result of the process which is thereby encompassed

is goods.

The third plank to our friend's argument seems

to be this, that a lacuna exists in the Act,

because one can have a use, which takes an article

out of the definition of "goods", without crossing

a taxing point as an application to "own use" and

we say that that is a misconception of the scheme,

that either there is an application to "own use",

in this case, of the negatives, by which a relevant

taxing point is crossed, or if that is not so,

there is no relevant use of the goods, because they

are not relevantly taken into "use or consumption"
and that the exception to "goods", in the

definition, of taking into "use or consumption", is

equivalent to one or other of the three crossings

of a taxing point, so that no lacuna exists between

application to "own use" and "use" within the
definition of "goods".

And the fourth plank to their argument, which is put in the alternative and put on the basis, if their arguments be wrong in relation to the

non-crossing of a taxing point, their fourth

argument is, if against them the court takes the

view that there has been an application to "own

use", then the negatives are excluded as "aids to

manufacture", because paragraph (k), in the

definition of "aids to manufacture'', is limited to

sales in fact, and we say of that last proposition,

that sales under the Assessment Act include deemed

sales and hence they apply, either because the

regulation or the provision in the Exemption and

Classifications Act is but part of the one

structure or, alternatively, because of a provision

in the Exemption and Classifications Act which

incorporates the meanings from the Sales Tax

Assessment Acts themselves.

And those four matters are, in our submission,

addressed in the argument as we develop it. In

speaking about the scheme of the sales tax

legislation, we have cited to Your Honours the
well-known passage in Ellis & Clark, to which I

will not take Your Honours. Brayson Motors, we

have set simply because it is a recent statement to

the effect that, notwithstanding that the analysis
of Sir Owen Dixon was made many years ago and in

circumstances where the structure of the

legislation was much less than it is now, this

Court has said none the less, that analysis still

Kodak(3) 53 7/4/92

holds good, notwithstanding that the changes had

been made, and that analysis and the passage from

Brayson Motors stresses that the structure or

scheme of the legislation is that all goods should

be taxed but taxed once only in the progress from

manufacture or importation into this country to

final "use or consumption".

The passage from Mr Justice Hill that we have

set out at the bottom of the first page, in his

analysis of the legislation we do not cavil, and we

submit to Your Honours that the analysis from

pages 36 to 38 of the appeal book is an accurate

analysis of the scheme of the legislation.

Reference has been made to the decision in

York Motors and the point has been made by our

learned friends that it was there said that the

three taxing points are alternatives. That is so.

It also appears from that decision that once one of

them is crossed, that is the end of the matter. In

other words, once one taxing point is crossed there

is no scope for the operation of the others, and

that was succinctly said by Mr Justice Williams at

page 468 - I am sorry, Your Honours, the citation

is 73 CLR 459, and the particular passage of

Mr Justice Williams is at page 468:

The tax becomes payable once and for all upon

the occurrence of any one of the three events

described in the section, namely: sale of the

goods by the manufacturer, their treatment by

him as stock for sale by retail, or their

application by him to his own us -

and in the Full Court of this Court, that

proposition was not doubted.

We have set out the proposition in general

terms at the top of page 2 that the scheme of the

will cause the negatives to be taxed if they are legislation as it applies to this particular case
goods which have been manufactured and have crossed
a taxing point unless they are the subject of an
exemption.

I should say in passing that it was common

ground at the time of the special leave application

in the Kodak matter, and I do not think it is

doubted - I will be corrected if I am wrong - but

there is no question of double taxation in this

case. The sale value with which Your Honours are

concerned is a sale value which is confined to the

processing charge in respect of the negatives,

which processing charge was not until, in any

event, the 1986 amendments picked up in the sale

value of the prints. So it is not a question of a
Kodak(3) 54 7/4/92

tax upon the unexposed film and a tax upon the

prints and now a new tax being levied that causes

the goods to be double taxed. The negatives are

not included in the process of determining the sale

value of the prints.

I might also say in this context that we agree

with the observation from our learned friend

Mr Bloom that the suggestion made by His Honour
Mr Justice Hill as to the way in which the

processing charge might be addressed differently

should not trouble Your Honours. We would submit

that the analysis of His Honour Mr Justice Hill may

well be wrong, depending upon the circumstances,
but it was not a matter which was argued and it is

not a matter which, in our submission, Your Honours

will be troubled with.

I should also say that if the Court is with us on the basis that the Commissioner is entitled to

tax the negatives, again there will be no question

of double taxation, because if there is a deemed

sale under section 17A(l), then the sale value is

picked up under section 18(1A)(b) and

section 18(1B) and confined to that processing

charge. If, on the other hand, there has been an

application of the negatives to the manufacturer's

own use, then section 18(3) applies, which again is

limited to the processing charge.

So that our first submission to Your Honours

is that one looks at the question whether the

negatives are goods and that, in our respectful

submission, is an easy question to answer, because

the definition of goods is a very wide one indeed.

The real question is not so much, "Do the negatives

fall within the definition of goods?", but, "Are

they excluded from that definition as second-hand

goods under paragraph (a) in the definition?"

Our learned friends have put the case that the

1986 amendments, which specifically included the

production of negatives within the definition of

manufacture, miscarried because there was no

corresponding amendment to the term "goods" to

include negatives specifically. We say that no

such extension was necessary because ''goods" is an

all-embracing term. The real question is whether

or not the exclusion of second-hand goods applies.

I made the general observation to Your Honours

earlier which we take up in paragraph 4 of our

outline, that there is a correlation between

manufacture and goods and that the outcome of

manufacture is goods. I should say this, that that

correlation, although it is fundamental to the

operation of the legislation, is not specifically

Kodak(3) 55 7/4/92

stated anywhere. There is not a specific provision

which enunciates that the outcome of manufacture is

goods, but none the less that is to be clearly

determined as a matter of construction of the

legislation.

If I take Your Honours first to the definition

of goods, to which Your Honours have already been taken, at page 92,141 of the booklet - I am using

the 10th edition and I think Your Honours may have
the 9th edition, but I do not think there is any

material alteration to the pagination - in the

definition of "goods":

"Goods" includes commodities -

so that the inclusive part of the definition is one

that takes the view that "goods", according to the
ordinary concept of that term, are naturally
included; it extends to commodities; and then there

are exclusionary provisions. The first one is the

one with which we are concerned, of course, and it

is the one to which Your Honours' attention has

been drawn, but I am highlighting the correlation

between "goods" and "manufactured", and that

correlation becomes apparent in the second

exclusion:

goods which are sold as second-hand goods and

are manufactured exclusively or principally

from goods which -

(i) have, whether alone or as parts of other

goods, gone into use or consumption in

Australia; and

(ii) in the opinion of the Commissioner, in

their condition as parts of the goods so

manufactured, retain their character as goods

or parts of goods which have gone into use or

consumption in Australia.

The definition of "manufacture", which is on the

next page, speaks in terms, in paragraphs (e) and

(f), of manufactured items being embodied in goods,

so that in (e) one has the embodiment of the

computer program in goods; the embodiment of the

images or sound in paragraph (f) in goods and,

further down, in paragraph (h):

so as to embody the program ..... in goods, by a
person who is not the manufacturer of the

goods.

So, again, the correlation between goods and

manufacture is highlighted.

Kodak(3) 56 7/4/92

"Manufacturer", the term defined on the next

page in the work:

means a person who engages, whether

exclusively or not, in the manufacture of

goods, and includes a printer, publisher,

lithographer or engraver, and a person (not

being an employee) who manufactures goods,

whether or not the materials out of which the goods are manufactured are owned by him, but,

where one person -

and then it goes on similarly to deem a position

and to exclude another. But again the correlation

is clear: goods are the output of manufacture.

Section 17(1), to which Your Honours'

attention has already been drawn, which is at page
92,214 of that work:

Subject to, and in accordance with, the provisions of this Act, the sales tax imposed

by the Sales Tax Act (No 1) 1930 shall be

levied and paid upon the sale value of goods

manufactured.

So that, again, the correlation is apparent

and without taking Your Honours to it, the similar

correlation is highlighted in section 19 to which

Your Honours have been taken and also to section 3

in the Rating Act to which Your Honours have been

taken.

So that, notwithstanding that there is no

specific provision that says the outcome of

manufacture is goods, in our submission, the

correlation is apparent. It is the goods

manufactured which is the subject of the impost

under this Act.

The reference to McNicol v Pinch, I will not take Your Honours to. It has be.en drawn to

Your Honours' attention already. Jack Zinader is

of interest because it is a case in which the

obverse of the proposition presently being put by

our learned friends was rejected. Jack Zinader is

in 78 CLR 336, and at page 344 to 345, the passage

on which I rely appears. Jack Zinader,

Your Honours will recall, is a case in which the

old furs were brought in, taken down, worn and

used, part excised, and the furs pinned out,

restretched for the purpose of being fabricated

into a replacement garment, and the High Court took

the view that this was a process of manufacture.

At the bottom of page 344:

Kodak(3) 57 7/4/92

On the whole the commissioner's view appears to be the more correct.

The work of

great value and usually of some permanence.

the furrier is to use skins to form garments.

His skill lies in the use he can make of them and the descriptions of garment he produces.

Fashion, commercial usage and his customer's

tastes combine to distinguish the various

descriptions of garment he makes and to compel

the recognization of them as separate

categories of "goods''. When he takes skins

made up into one description of fur garment

and produces another, he cannot be treated as

having altered an existing thing without

producing a new one. He has made a different
article.

But on behalf of the taxpayer answers to

this position are put forward by way of

confession and avoidance. Let it be so, it is

said. Nevertheless there is no

"manufacture" -

so the proposition which was there being put was

goods without manufacture. The opposite is being
put to Your Honours.

The process does not amount to manufacture.

It is not manufacture within the ordinary

meaning of the word nor within the statutory

definition. It is a reshaping or reforming of

an existing second-hand article. Taking a

thing to pieces and putting it together again

is not manufacture and putting it together in

a different shape is not enough to make

applicable the word "manufacture." So runs

the argument. The argument is answered by the

consideration that, according to the

conclusion already stated, the process
produces a different article. When that

consideration is added to the fact that the

actual work done and the procedure employed in

producing the new, that is the distinct,

article is characteristically a manufacturing

process, it must follow that the "goods" are

"manufactured" within the ordinary meaning of

that term.

MASON CJ: But how far does that take you, because if you

look at page 347 in the paragraph commencing on

that page, His Honour evidently regarded it as

necessary to establish that the goods were not

excluded by paragraph (a) of the definition of

"goods"?

Kodak(3) 58 7/4/92
MR GZELL:  Yes, quite so, Your Honour, but the question was

whether or not there was to be an exclusion by

reason of a failure to overcome the proposition

that there was manufacture, so the proposition

which was being put was that if this was not a case

of manufacture, then the old goods, the old fur,

being second-hand goods, fell within the exception.

The argument which succeeded, of course, was that

because that which was fabricated out of the old

furs was a process of manufacture, new goods were thereby created, and since new goods were thereby

created, there could be no scope for the operation

of the exclusion of paragraph (a). And likewise

here, if our friend's argument succeeds and there

is no process of manufacture creating a new good,

then the goods, which are the negatives, are

excluded as second-hand goods; they have already

gone into use in respect of the sale by retail of

the unexposed film to the customer.

If, on the other hand our argument succeeds

that the negative is a new good produced by a

manufacturing process, there can be no scope for the operation of paragraph (a), because that new

good is something distinct from the exposed film

that resulted from that which was bought by the

customer, and one then does not regard that new

good, the negative, as falling within the

second-hand exclusion in paragraph (a). So that

the proposition which we then address is that the

making of the negatives is a process of manufacture

according to ordinary concepts.

Our learned friend, Mr Bennett, said to

Your Honours that all that happened was a simple

chemical process. Well, it may be simple to him;

it is not so simple to me. There are a series of
steps, the evidence in both cases reveal, which are

taken in respect of the exposed film to produce the

negative. I do not intend to take Your Honours to
it, but I draw Your Honours' attention to

Mr Forbes' affidavit in the Kodak matter at appeal

book page 36 and his second affidavit at appeal

book page 40, and in the Genex matter, in the case

which is stated, particularly at paragraphs 7 to 27

at the appeal book 10 to 18. But, very simply,

what appears from Mr Forbes' affidavit is that the

first thing that happens to the exposed film is

that it is taken through a developer solution and

the purpose of taking it through the developer
solution is that, what are described as couplers,
are converted into dyes, the couplers being in
various layers on the underlying plastic, and in
addition, the negative image is produced by the

production of metallic silver.

Kodak(3) 59 7/4/92

The second process that then occurs is one in

which it is introduced to a bleacher and the
bleacher has the effect of making the metallic

silver soluble. It then goes through a fixing

solution under which the metallic silver is removed

and then through a stabilizer which preserves the

image and finally through a drying process and, in

the course of that simple chemical process, there

is, in our submission a change in the nature of the

exposed film, both chemically and physically and,

furthermore, it is a commercially different thing

because if one takes the exposed film and submits

it to light it will destroy any latent images that

are in it and the result of the process of

producing the negative is that it is resistant to

the application of light.

In our submission, Mr Justice Mcinerney got it

right in his analysis of the matter in the Kodak

appeal book at page 44 to 45, and the approach that

was taken by Mr Justice Mahoney on the one hand and

Mr Justice Hill in their respective judgments on the other, is to be rejected, in our respectful

submission. Mr Justice Mahoney took the view that

because the Exemptions and Classifications Act

recognizes goods by description, what the goods in

this case were was a photographic film, not an

unexposed photographic film, not an exposed
photographic film, not a photographic film

producing negatives, but a photographic film, and

on that basis the description being of a

photographic film, he took the view that the change

which was wrought between the stage of exposure and

the stage of producing the negative was not

manufacture.

Mr Justice Hill approached it from the point of view that this was a service involving a

modification of existing goods and being a service

goods. But, in our respectful submission, the involving merely a modification did not create new
material difference in physical composition, in the
physical structure and in the commercial usability
of the end result is sufficient to constitute it as
a manufactured good.
Reference has been made to McNicol. The

distinguishing feature about the McNicol case was

that you had saccharin which had what were called

"para" compounds within it, and "para" compounds

had no sweetness, so the extent to which you had

"para" compounds mixed up within the saccharin, the sweetness was reduced relatively to the bulk of the

product.

What happened in McNicol was the removal of the "para" compounds, thereby increasing the

Kodak(3) 60 7/4/92

quantity that was saccharin and thereby increasing the sweetness. One can understand in that sort of

circumstance saying that that was not a process of

manufacture because what was produced at the end

was the same as before and an impurity, if you

like, had been removed.

Jax Tyres may be a little difficult to

reconcile with Jack Zinader. In Jax Tyres, like

Jack Zinader, one had old tyres, and a retreading

process was added to them. The Court took the view

that the retreading process did not create a new

article. I suppose one way of distinguishing Jax

Tyres from Jack Zinader is that in Jack Zinader,

the fur was taken for the purpose of excising that

which was no longer serviceable and utilizing what

remained in restructuring a garment. That amounted

to manufacture, whereas in Jax Tyres, an old tyre

was taken, its surface was cleaned and it was

repaired by the extrusion of new tread.

Our learned friend, Mr Bennett, put some

stress on the fact that this case is different

because the film is bought with the very purpose of

having created from it a negative for the very

purpose in the end of producing prints. So he says

it is like the butterfly emerging from the

caterpillar.

The same thing applies, in our respectful

submission, to the Jack Zinader case. One starts

off with a fur that might be likened to a

caterpillar for a different reason, excises those

portions of it that are no longer beautiful and

produces a butterfly as the end result. It is

certainly not a case of making a silk purse from a

sow's ear, because the ingredients for the final

product existed.

We cavil with our learned friend's submission

that this case is unique. In WEA Records v Federal

Commissioner of Taxation, Mr Justice Davies had to

consider whether or not the recording on to a tape

was a process of manufacture. That is very much

the same sort of situation to which our learned

friend, Mr Bennett, alludes, because the tape is

acquired for one purpose and one purpose only: to

have reproduced on to it the sound images or the

light images or both, as the case may be.

Mr Justice Davies had little difficulty in

concluding that the end result of that process was

one of manufacture. We take comfort from that

decision because if the process of recording is

properly regarded as a matter of manufacture, then

so too, in our respectful submission, is the

concept of developing. What His Honour
Kodak(3) 61 7/4/92

Mr Justice Davies said - and the case is reported

in 96 ALR 365. The passage I wanted to take

Your Honours to is at page 370:

In my opinion, the duplication process

undertaken by Image and Videocopy brought into

being a commodity which was different from the

blank cassettes on which the videos were

recorded. A cassette adapted to take a video
recording is one thing. A cassette containing

a video recording is another, as Mr Byron

recognised in his evidence. The commodities

are different because the video recording,

which is the predominant feature of the one,

is absent from the other. The process whereby

this occurs is not mere treatment but

production and, to my mind, manufacture, using

that term in its ordinary sense.

DEANE J: But that would really support the view that there

was manufacture at the time of exposure. It does

not support the view that there is manufacture when

the exposed film is treated because the equivalent

to what is put on the tape has already been put on

the film.

MR GZELL: 

I take Your Honour's point because in the process of taking the tape and putting on to the surface of the tape metallic substances which give signals,

there is but one process involved. Whereas here,
in order to get to the negatives one goes through
two processes, that is, the images are cast in
negative form on to the exposed film which is then
stabilized by the process of taking it from exposed
to negative. So I take Your Honour's point. But
none the less, the process - I mean, one of the
points that was being made against us was that one
cannot envisage a function of manufacture if that
which is- done is the very thing for which the i tern
is brought into existence, and that case is with us
in challenging that proposition, although I take
Your Honour's point as to the distinction between
the one process there and the two processes here.

It is pointed out to me, of course, that if

one is talking about dividing the dual process that

goes on in exposing a film and then producing a

negative from it and comparing that which gives it

the quality of being a new product, one must

include the step of producing the negative because

there is nothing of lasting quality about the

exposed film. Unless one takes the next step and

stabilizes the latent image which the light has

produced on the sensitive paper, one has got

nothing like the cassette recording that one had in

the WEA case; so that albeit that there is a

double step in the situation with which

Kodak(3) 62 7/4/92

Your Honours are concerned, our submission is that

it is the second of the two steps which gives the

quality to the product which enables it to answer

the description of a good manufactured.

The other thing that I should say, and I

omitted to say in indicating to Your Honours the

way in which His Honour Mr Justice Hill had

approached the question in Genex, is that

His Honour ultimately did not form a concluded view

as to whether or not the creation of the negative

was a process of manufacture according to ordinary

concepts. He said it was unnecessary for him to

finally decide that issue, at page 55 in the Genex

record, because of the view he took about the

extension to the definition of "manufacture''. So,

outline 5: "In the end it is not necessary to come

to a final conclusion on the matter".

There are a lot of cases, as my learned

friend, Mr Bennett, indicated to Your Honours; a

number of them are summarized in the Jax Tyre

decision and His Honour Mr Justice Hill adds a

number of others to it in his analysis but, in the

end, it does not assist simply to compare the

factual situations that have been held to fall on

one or other side of the fence. Ultimately it is a

matter for Your Honours' judgment and I leave that
question and pass on to the next.

That is, that in any event the extension of the definition of "manufacture" carried with it -

because of the correlation which we say underpins

the scheme of the legislation - the consequence

that negatives are goods. And this is not a

question, like the decision of Comber to which our
friends referred, of deeming one thing to occur but

not deeming the other to occur, because Comber did

not involve a scheme which treated as a fundamental

which simply says, "We extend the definition of concept the output of manufacturers' goods and, that being the underlying concept, a definition
manufacture", carries, as part of the structure,
that concomitant.

That proposition did not concern

Mr Justice Williams in the slightest because, in

Jack Zinader, to which I have already made

reference, 78 CLR 336 at page 349 - and I apologize

to Your Honours, in paragraph 6 of our outline the

reference there should not be 346 but 349 - at

page 349, admittedly His Honour did not have the
precise point that Your Honours have before you but

he did not find any difficulty in regarding goods

as being the outcome of an extended definition of

the term "manufacture". At page 349, about

two-thirds of the way down that page:

Kodak(3) 63 7/4/92

The Act therefore applies in terms to all

goods which are goods or commodities in the

ordinary meaning of those words except those

goods which are excluded by pars (a) and (b)

of the definition. The Act also applies in

terms to all goods which are manufactured

according to the ordinary meaning of that word

or which are manufactured within the meaning

given to that word by the definition.

And we say that that approach is perfectly proper

in circumstances where the correlation underpins

the scheme.

Our learned friend, Mr Bloom, put some stress

upon provisions introduced into the Act at the same

time as the extension to the definition of

"manufacture", and his submission to Your Honours

was this, that paragraph (d) - and I am now back at

page 92,142 of the work - our learned friend,

Mr Bloom, pointed out that paragraph (d) was not

introduced alone in 1986, but paragraphs (e)
and (f) were also introduced at the same time, so
that the definition was extended not only to cover
the development of negatives but also the embodying
of computer programmes in goods and the embodying

of images or sounds or both in goods under

paragraphs (e) and (f).

Our learned friend said, "Well, in addition to

the definitional additions in paragraphs (e)

and (f), there were specific provisions introduced

at the same time to underpin (e) and (f), and

because there was no additional provision

introduced to underpin (d), that suggests a

legislative intent to treat (d) separately from (e)

and (f)". We cavil with the proposition. Our

learned friends took Your Honours to sections 3(3A)

and 18B as the underpinning of paragraphs (e)
and ( f).
Might I take Your Honours to section 18B

first, and that appears - at least in my edition -

at page 92,264. Now, 18B has gone through further

revision since it was introduced in 1986 and the condition of the legislation then appears in the footnote in the small type at page 92,271. What is

apparent, when one looks at the form of the section

when it was introduced in 1986, or if one looks at

the form of the provision now, is that it addressed
a totally different question. It addressed the
question where one, for example, copies a - or a

manufacturer produces some computer software on a

floppy disc and the manufacturer sells you the

floppy disc for two and twopence but charges you a

licence fee to utilize what is on the floppy disc

for thousands of dollars. It was in order to

Kodak(3) 64 7/4/92

overcome that problem of bifurcating the

consideration for the commodity between a licensing

of its use and the sale of the good that

section 18B was addressed to.

If one looks at the small part of it, it talks

about, paragraph (a), where -

goods in which visual images or sounds, or

visual images and sounds (any of which are, in

this section, referred to as the "embodied material") have, or a computer program (in this section also referred to as the "embodied
material") has, been embodied, have, after

19 August 1986, been -

(i)     sold by the manufacturer of the goods to

an unregistered person or to a registered

person who has not quoted the person's

certificate in respect of the sale; or

(ii)  treated by the manufacturer of the goods

as stock for sale by retail.

And then, if·one goes to page 92,271, to see what

it was like when it came into existence:

(b) where sub-paragraph (a)(i) applies -

that is it has been sold -

valuable consideration (in this section

referred to as the 'licence fee') has been

given by the purchaser or another person to

the manufacturer or another person in

connection with, or as consideration for, the

supply of, or the right to use, the embodied

material in the goods;

or, if it is held in stock -

(c) the sale value of the goods for the

purposes of this Act would not, but for this

section, include the val_ue of the licence

fee -

then the provision goes on to say that the sale

value is to include the licence fee. And

section 3(3A) covered the situation where, instead

of the manufacturer selling the floppy disk, he

gave the floppy disk away, but still charged the

licence fee and section 3(3A), which is at

page 92,161 provides:

Where goods to which section 18B would apply

if the goods were sold by a person to another

person are given by the first-mentioned person

Kodak(3) 65 7/4/92

to the other person then, for the purposes of

this Act, the first-mentioned person shall be

deemed to have sold the goods to the other

person.

So that both of those provisions address a totally

different concept and do not affect the notion that

we submit to Your Honours that there was a

deliberate extension in 1986 of the definition to

cover the processing of negatives, the computer

programme or visual or sound image reproduction as

well.

We then go on to give Your Honours a reference

to Cooper Brookes. Our learned friends have taken
Your Honours to Hepples. We might add to that the

observations of this Court in Mills v Meeking,

which is on our part B list, but I can give

Your Honours the passages on which we rely in Mills

v Meeking, 169 CLR 214 at pages 223, 235, 242 to

243.       I do not propose to address Your Honours on

the Cooper Brookes point. It is an area which is

well known to Your Honours. We say that there is a

construction, we do not need to go to the extent of

saying, in our primary submission, to Your Honours

that the result would be absurd and therefore fix

the absurdity; we just simply say that the

interpretation which we have put is open and it is

an interpretation which gives effect to the

legislation and it to be preferred to any

over-literal interpretation which denies that

effect. ·

At paragraph 8 of the outline we address the

first of the two applicable taxing points in this

case; the third, clearly on the facts of the case,

being irrelevant. And I said to Your Honours

earlier that either what is done with the negatives

by the manufacturer is properly to be regarded as

an application to own use by the manufacturer, in

which case the taxing point is then crossed

or - - -

DEANE J:  Does that not conceal a possible problem and that

is, if you look at page 16 of the Genex book,

paragraph 26, there is a complete process by which

the complete negative film is cut up, put into

sleeves to produce the final product that is handed

back to the customer; now why would you not regard

the relevant process of manufacture, either under

the definition or as a matter of ordinary language,

as extending from the stage when processing

commences up until the stage where the separate

negatives are cut up and put into containers? I

mean, in one sense that is the most dramatic thing

that happens in this whole process in terms of - we

Kodak(3) 66 7/4/92

are talking of manufacture because you end up with

quite distinct separate products.

MR GZELL: Well, if that is so and one takes the

manufacturing process - - -

DEANE J: Well, perhaps in fairness I should indicate where

the question leads, because if your answer is to

assent to that - - -

MR GZELL:  I was not going to, Your Honour.
DEANE J:  - - - it would mean the application for use has

been before the process of manufacture was

complete.

MR GZELL: Quite. That was the first observation I was

going to make. If that is so then there is no

question of an application to "own use" because

that proceeds the end of the manufacturing process

on that analysis and therefore we do not have the

problems that our learned friends raise in respect

of their contention that section 17A(l) can have no

application, because at the end of the

manufacturing process there has been no application

to "own use" - after the "good" has been

manufactured there has been no application to "own use" and on any view section 17A(l) would then not

be circumscribed by the sort of problems that

Your Honours have been addressed with.

In our respectful submission, the

manufacturing process of the negative - and

certainly this is the way the case has been fought

on both sides - concludes when the negative has got

to that stage of stability and completeness,
thereafter it being used in the production of

prints and ultimately chopped up and put into

sleeves and the rest, is a process which occurs

after the manufacturing process has concluded.

I accept what Your Honour puts to me as a

possibility. If one analyses that possibility,

then, with respect, the arguments that have been

advanced to the Court by the other side fall by the

wayside because one then has a clear section 17A(l)

delivery of manufactured goods which remain goods

at the point of delivery, because there has been

subsequent to their manufacture no application to

"own use" or "no use". But that certainly has not

been the way that we came to the Court to grapple

with the problem.

DEANE J:  And it is not the way you put it.
MR GZELL:  Your Honour, I accept it as a possibility and if

that approach be the correct one, then we win, with

Kodak(3) 67 7/4/92

respect, because what flows from that is a pure

section 17A(l) situation on delivery of the

negatives, but we are prepared to grapple with it

in the way in which both cases have been argued

below. On that basis, we analyse the two

alternatives, assuming for this purpose that the

manufacturing process concludes when the negative

is produced in its final form.

When I say in its final form, I did not mean

the end of the cutting up process, but when the

negative has been taken through the drying process

and is then in the condition in which it will

ultimately emerge to be cut up and put into the

sheaths and is then in the condition in which light

may be shone through it to produce the reverse and

positive image.

The first alternative is that when the taxpayers use the negative to shine light through

it to produce a latent image on the sensitized

paper - and I should just briefly say that the
process of producing the prints is a repetition, as

it were, of the process by which the negatives have

been produced. A light is shone through the
negative on to sensitized paper. The sensitized

paper takes up a latent image, positive this time

rather than negative, and then the processes of

converting the couplers to dyes and of removing the

metallic substances are again taken through to the

ultimate production of the print.

The first proposition that we advance to

Your Honours is that the use that is then made of
the negatives, albeit that they are not owned by
the manufacturer, the use which is then made of the
negatives is an application to own use by the

manufacturers and a taxing point under

section 17(1) is then crossed. That does have an

attraction to it because the alternative to that

proposition is that there is no use within the
sales tax legislation for a negative, and as our

learned friends pointed out to Your Honours this

morning, Mr Justice Hill rejected a submission that

we had then made that the shining of the light

through it was not a use at all, rejected that

proposition on the basis that if that were so there

was no relevant use that the negatives had. So

that there is some attraction ·.n saying if :he very

purpose of a negative - as our learned frie~ds have

submitted to Your Honour, we appear to be ad idem

at this stage - if the very purpose of the

negatives is to have light shone through them to

produce prints, then why is that not a relevant

use, and why is it not, we ask rhetorically, an

application to own use by the manufacturer? Why

should a manufacturer have to own something before

Kodak(3) 68 7/4/92
he can apply it to his own use? We say that that

is not necessary, albeit that we cannot point to a

case in which this has occurred.

The Max Factor case, the Taubmans case, the

Hornibrook case, have been drawn to Your Honours'

attention already. They establish, in our

respectful submission, that there is an application

to own use if a manufacturer employs goods for his

own purposes. They do not stand for the

proposition that there cannot be an application to

own use unless the goods are owned. Our learned

friend, Mr Bloom, places weight upon the use of the

word "own" to submit to Your Honours that unless

there is ownership in the goods there cannot be an

application to own use. But, in our respectful

submission, the Act does not say that. The word

"own" is not used in the sense of qualifying goods

and suggesting ownership. The word "own" is used
to qualify the use.
BRENNAN J:  How then do you account for section 18(3)?
MR GZELL:  I take the point that my learned friend,

Mr Bloom, addressed to the Court, and that is that

one would not normally expect a figure in respect of a sale by the manufacturer unless it was owned

by the manufacturer, but again, section 18(3) does

not say so. Certainly it will deal with the

situation where that which is used is owned by the

manufacturer, but on the plain words all it
requires is a determination of what would have been
received had it been sold by a manufacturer, and it
does not exclude the possibility that that question

of an hypothetical sale figure can be determined,

irrespective of ownership.

BRENNAN J:  How then do you determine the sale value of

goods applied to own use by a manufacturer who does

not own them.

MR GZELL: 

By having in mind the cost of processing the negative.

So that if the negative in this case

were utilized by the manufacturer in the process of

developing the - I am sorry, I was not fast enough

to pick up the observation that my learned junior

was trying to feed to me. It is a further

expansion of what I had put to Your Honour Justice

Brennan, and that is this - might I, before I

specifically answer, because I was about to say

there are a number of provisions in the scheme of

this Act which require hypothetical sales to be

considered. For example, if there is a retail sale

which is involved, then what one must determine is

what the wholesale price would have been rather

than the resale price, if there is no wholesale

sale which is affected. So it is not unusual to
Kodak(3) 69 7/4/92

consider what would be achieved on an hypothetical

sale.

To answer Your Honour Justice Brennan, 18(3)

works quite logically if one assumes that - and if

one considers 18(3) on the basis that title to the
goods passes from the customer to the manufacturer,
for the purpose of then determining what price the

manufacturer would recover in respect of a sale of

that good to the figure which is attributed to him

on an application to own use. Or, the way in which

I was seeking to answer Your Honour was saying, all

one is asked to do is to presuppose that there is a

sale of the negative by the manufacturer and one

does that by considering the ci~cumstance that the

manufacturer has produced the negative at a cost

and the Act requires one to consider what, in an

hypothetical sale situation, the manufacturer would

recover for it if he sold it.

And that, in our respectful submission, does

no damage to the language of the Act and accords
with the artificial notions of sales which must be
supposed throughout the structure of the Act in
circumstances where the only indicator of a

wholesale sale value is a retail sale, and one has

to suppose what would have happened if the goods

had been sold by wholesale.

BRENNAN J:  The hypothesis being that the title passes from

the customer to the manufacturer for the purposes

of a sale by the manufacturer to the customer.

MR GZELL: For the purposes of underpinning an hypothetical

sale.

BRENNAN J: But only to the customer.

MR GZELL:  No.

BRENNAN J: Usually people do not want other people's

photographs.

.

MR GZELL: That is right, Your Honour. It is not only to

the customer, except that one certainly would not

ex~ect anyone other than the customer to be the not

ov~ -anxious bidder in the market-place. Indeed,

You Honour is quite right in putting the

pro ~sition to me because of the uniqueness of

one's own films. There may be circumstances - I

retract that - in which there is a ready market for

a negative which some other person would not like

to see utilized to produce prints, but apart from

that exceptional sort of circumstance, one would

normally suppose that the value which is attributed

under 18(3) is the cost of processing because the

only likely person in the hypothetical market is

Kodak(3) 70 7/4/92

the very person whose prints are going to be

produced. If, in order to underpin that

hypothetical sale one has to imagine an

hypothetical transfer of title from the customer to

the manufacturer and then back again, so be it.

I am reminded that in the case of

Estee Lauder, which my learned junior tells me is
reported in 88 ATC, but his photographic memory

does not tell me the page, the question of what one

does do about supposing circumstances when dealing

with hypothetical sales arose, and it was held that one does not suppose more than is necessary for the

statutory hypothesis to work. So that, all that is

required in this circumstance is that there be an

hypothetical sale by a manufacturer of negatives.

I had been saying to Your Honours that the

word "own" does not qualify the goods but qualifies

the use, and to make that good I take Your Honours

back to 17(1) at page 92,214:

Subject to, and in accordance with, the provisions of this Act, the sales tax imposed

by the Sales Tax Act (No 1) 1930 shall be

levied and paid upon the sale value of goods
manufactured in Australia by a taxpayer and
sold by him or treated by him as stock for

sale by retail or applied to his own use.

So that the word "own" is not there qualifying

the goods, it is qualifying the use that is made from them. Our learned friend, Mr Bennett, said

"Well, it is really a use of the customer and not a

use of the manufacturer". In a sense that is true

in a sense that it is for the use of the customer

to get his prints that the manufacturer utilizes -

to use a neutral term - the negatives. But the

fact that you have somebody with a use does not

mean that you cannot have concurrent uses and that

was clearly the case in Stewart, 154 CLR 385, to

which reference was made this morning, in

particular at page 397 in the judgment of

Your Honour Mr Justice Brennan, where,

notwithstanding that two different persons could
have a use for it, the one did not exclude the

other. About two-thirds of the way down the page:

The use by a public benevolent

institution referred to in item 81 is not

necessarily exclusive of the use of the goods

by others. Indeed, the use of particular

goods by others is often the use intended for

them by public benevolent institutions -

hospital beds, for example. But the proposed

use by a public benevolent institution must be

sufficiently substantial in extent and time

Kodak(3) 71 7/4/92

that it is right to regard that proposed use

of the goods as giving a character to the

goods.

And there were two cases in the Full Court of the

Federal Court dealing with wheelie-bins, the
disposal garbage bins which, unlike my friend
Mr Bennett's refrigerator, did have wheels on the
bottom of them, and the question was,
notwithstanding that the wheelie-bins were used by
ratepayers for the purpose of putting their rubbish

out was there also a relevant use by the local

authority which would bring them within one of the

exemptions under the Exemptions and Classifications

Act and in one case the court held that it was and

in the other case it held that it was not. Those

two cases are Otto and Brambles. They are probably

reported elsewhere, I am sure that they are

probably in the Federal Court Reports, but they

are, in any event, reported in (1990) ATC 4605, and

Brambles at page 4584. I am told that is at first

instance, which means that - we will get

Your Honours the reference, but the appeals will be

in (1991) ATC in both matters.

So that, notwithstanding that it may be an

unusual circumstance and notwithstanding that at
the time the particular provisions were introduced
into the Act this question was not in
contemplation, none the less there is nothing in

the legislation which would preclude, in our

submission, a utilization to own use,

notwithstanding that there is a lack of ownership.

Now, there are circumstances in which a

manufacturer will not necessarily own goods at the

time of manufacture. Section 17A(l) is a prime

example, because that is the circumstance in which

the goods are provided by the customer; no question

of ownership of those goods at the time of

manufacture. Section 18(1A) is another example.

Section 18(1A) is at page 92,223.

Where -

(a) goods that have been sold by the

manufacturer after 20 September 1978 to

an unregistered person or to a registered

person who has not quoted his certificate

in respect of the sale -

(i)     were manufactured for the purchaser in

whole or in part out of materials
supplied by the purchaser;

So again, the situation in which, at the time of manufacture, ownership of the goods is not in the

Kodak(3) 72 7/4/92

manufacturer, and yet a taxing point that applies

as one of the alternatives throughout the (No 1)

Act is an application to own use. And that is

echoed in the definition of "Manufacturer" at

page 92,143:

"Manufacturer" means a person who engages -

and I will miss a number of lines and take

Your Honours down to -

whether or not the materials out of which the goods are manufactured are owned by him, but,

where one person manufactures goods for

another, wholly or in part out of materials

supplied by that other -

So that, at a point immediately after manufacture

with which we are concerned, it may be that

ownership is not in the hands of the manufacturer.

Whenever I pose an example, it always

misfires, but I will try. Let us suppose that I am

a manufacturer and in order to construct the wheels
for Mr Bennett's refrigerator, I need a template or

a jig or something of that nature, and I am

supplied with the materials by Mr Bennett and from

those materials I construct this jig or template or

mould and I then use that to honour my contract

with him of producing a refrigerator with wheels on

it. Now, in that circumstance, in our submission,

there is an application to my own use of the jig or
the template or the mould or call it what you will,

and yet I do not own it, but it is an application

to my own use, notwithstanding that I do not own

it, because the only way in which I can honour the

contract of producing the end result is to use this
thing in that process, and in our respectful

submission, there is no reason in the legislation why the concept of application to own use must be

limited to ownership in the manufacturer, albeit

that it is an unusual circumstance.

The analysis of this matter by His Honour

Mr Justice Hill at pages 59 to 61 of the appeal

book in Genex is to be rejected, in our respectful

submission, because it misconceives an issue.

His Honour poses the problem of double taxation.

We say that it does not arise and it does not arise

- and the example he gives is at page 61 - because

if the negatives are delivered without having been

used to make prints, there is a sale, there is a

deemed sale under section 17A(l), and if there is a

deemed sale under section 17A(l), then one of the

taxing points under section 17(1) is crossed. The

negatives have gone into use or consumption because

they have been sold and thereafter, when the

Kodak(3) 73 7/4/92

negatives are redelivered, under the example, to

produce prints, they are no longer goods because

they are being taken out under paragraph (a) as

second-hand goods.

Your Honours will recall that, in York Motors,

not only were the three taxing points said to be

alternatives but it was made clear that once one is

crossed, that is the end of the matter. So that

His Honour Mr Justice Hill, in our submission, at page 61 of the record, has misconceived what

happens when the taxing point is crossed. In other

words, if the taxing point of sale is crossed, one

does not have to use them in order for them to be

taken out under use and consumption. The very fact

of retailing is that which constitutes the use and

consumption for the purposes of section 17(1).

Your Honours, the alternative argument which

we address at paragraph 12 is the answer to the

suggested lacuna that I mentioned at the beginning

of our submissions. Section 17A(l) is not a

provision which deems a taxing point to come into

existence. It is a provision which simply deems a

sale to have occurred. And one goes back to

section 17(1) for the purpose of determining

whether or not a taxing point has been crossed.

Section 17A(l), where goods have been:

manufactured in whole or in part out of

materials supplied by the customer,

manufacturer of the goods shall, for the

purposes of this Act, be deemed to have sold

the goods to the customer at the time when the

goods were delivered to the customer.

It says no more. It does not say that the goods
thereby become exigible to tax under the Act. It
is s1mply a provision which deems a sale to have
occurred. One then goes back to section 17(1) and

asks the question whether, by reason of the sale, a

taxing point has been crossed.

So there is absolutely no reason in section 17A(l) to concentrate on the taxing point

which our learned friend, Mr Bloom, submitted to

Your Honours. This is not a taxing provision. It

is a deeming provision. It is for the operation of

section 17(1) to determine whether a taxing point

has been crossed. If one looks at 17A(l) from that
point of view, it simply deems a sale to have
occurred, and one goes back to 17(1) to determine

whether the taxing point has been crossed.

If one then looks at 17(1) from the point of

view of whether or not upon the deemed sale having

Kodak(3) 74 7/4/92

occurred the negatives answer the description of

"goods", our friends' argument, put into the

context of section 17(1), is that they are no
longer goods for the purpose of determining whether
they cross the sale taxing point in section 17(1)
because they fall within paragraph (a) of the
definition of "goods" at page 92,141 because, our

friends say, they are goods which have gone into

use or consumption.

Our answer to that is that there is no taking

into use or consumption relevantly for the purpose

of the exclusion in paragraph (a) unless the goods

have been taken across a taxing point. If one goes

to the exclusion in paragraph (a) of "goods" at

page 92,141, what is excluded are -

(a) goods which have, either through a process

of retailing or otherwise, gone into use or

consumption in Australia.

Our friends are saying the negatives are not used

by the manufacturer in an application of "own use",
but nevertheless, they have been used for the

purpose of excluding them from the definition of

"goods" in paragraph (a); and the consequence is

that they point up a lacuna in the structure of the Acts, the lacuna being circumstances in which there

has been a use which has not been sufficient for

whatever reason, to take the goods over a taxing
point of application to own use, but none the less,
they say, thereby render them second-hand goods for

the purposes of paragraph (a).

If that is right as a matter of construction,

the legislation has miscarried in respect of the underlying scheme of taxing all goods but taxing

them only once, because goods such as these fall

into the gap between application to own use and

exclusion. We say that it is not every use or
utilization of goods which brings a matter within

the exclusion in paragraph (a).

The type of use or consumption is pointed up

by the reference to one of the bases of crossing

the taxing point: retailing. In our respectful

submission, the taking into -use or consumption for the purpose of the exclusionary paragraph is those very alternative activities which constitute the

three taxing points in section 17(1).

So that, going back to section 17(1), if goods

are sold by the manufacturer, they are taken into

use and consumption. If they are treated by him as

stock for sale by retail, they are taken into use

or consumption. If they are applied by him to his

own use, they are taken into use or consumption.

Kodak(3) 75 7/4/92

Any use which falls short of that is not a relevant

use for the purpose of the exclusion.

Your Honours will recall that that paragraph

was introduced into the Act to enshrine the

decision in Ellis & Clark, Ellis & Clark being

concerned to ensure that a sale of second-hand

goods should not be regarded as falling within the

literal meaning of the words in the Act and the

legislature having reacted to that by a passage of

words which echo the judgments, as has been said by

this Court in subsequent cases.

So that when one looks at the history by which

paragraph (a) came into the Act and when one looks

at the structure of the Act which excludes from the

definition of "goods" those which have been taken

into use or consumption, that composite phrase "use

or consumption" carries a meaning, and the meaning

is that which takes the goods over a taxing

threshold, for otherwise the policy of ensuring

that all goods are taxed, but only once, would

miscarry.

It would be silly, in our submission, to think

in terms of some uses excluding the goods but yet

not amounting to application for own use. A couple

are posed by Mr Justice Mahoney in the course of

his judgment. Suppose, for example, in Jack

Zinader, that in order to determine the way in

which the garment would properly hang, an employee

of Jack Zinader wore the fur, that is a use in one

sense, but is that a use which is going to exclude

the garment from the category of goods as a use or

consumption in paragraph (a), and we would say, no.

If one approaches it from the basis that it is

not every use, clearly the section does not posit

that every use is one which is going to exclude

commodities from the definition but only those by

which, whether by retailing or otherwise, the
articles go into use or consumption, one sees a

congruent construction for the Act which avoids the

lacuna that our friends have pointed up.

BRENNAN J:  Mr Gzell, in the event of reliance upon

section 17A, what is the sale value of the goods?

How does one ascertain it?

MR GZELL:  Your Honour, 17A is a deemed sale concept. One

then comes back to specific provisions in the Act which deal with the value to be attributed to it.

The first provision that one looks at is

section 18(1A)(b), and that is at page 92,224 - at

least in my edition; so far they are the same -

which says where:

Kodak(3) 76 7/4/92

(b) goods -

(i)        have been manufactured in Australia for

a person in whole or in part out of materials

supplied by that person;

(ii) are deemed by section 17A to have been

sold by the manufacturer to that person; and

(iii) the person to whom the goods are deemed

to have been sold was an unregistered person

or a registered person who had not quoted his

certificate -

then one goes to 18(1B) and one goes
to 18(1B)(c)(ii) relevantly in this circumstance: Subject to sub-section (4A), the sale value of

goods to which this sub-section applies is -

(c) -

because (a) and (b) do not apply -

in any other case the sum
and we are not concerned with (i). We go down to
(ii): 

the amount charged to the purchaser by the

manufacturer in respect of the goods.

BRENNAN J: (c)(i) does not apply?

MR GZELL: (c)(i) does not apply.

BRENNAN J:  Thank you.
MR GZELL:  So that it is the processing charge that I
mentioned earlier. I think I had said all I wanted

to say about paragraph 13 in our outline.

Paragraph 14 takes up the construction point in respect of section 17A(l), which was put by one of

Your Honours this morning - I think it was

Your Honour Justice Brennan. Our learned friend,

Mr Bloom had said one looks at 17A(l) conscious of

the taxing point; we say that that is not so.
Section 17A(l) is merely a deeming provision as to

what is a sale and the question of the taxing point

is dealt with elsewhere in the legislation. And if

one simply looks at it from the point of view of it

being a deeming provision in relation to sale,

there is no reason why, in our submission, one

should construe it to require that that which is
delivered still answers the description of goods.

Now, I am on to an alternative argument clearly enough here, because thus far I have said to

Kodak(3) 77 7/4/92

Your Honours that, either there is an application
to own use by the manufacturer, in which event the

Commissioner is entitled to tax as an application

to own use or, the alternative argument is, if that

is not so, the use that is made of the negatives is

not a use which takes them out of the definition of

"goods" and therefore at all points in the analysis

of section 17A(l) the negatives answer the

description "goods" and 17A(l) deems a sale to

occur, go back to 17(1) and there are goods which

are sold and a taxing point is crossed.

This argument is one which I must address if

Your Honours are against me; if Your Honours take

the view that there is a difference between

"consumption or use" in paragraph (a) of the

definition of "goods" and application to own use is

one of the taxing points in section 17(1). And

this argument says, well, notwithstanding that, all

that is required by section 17A(l) is that the

negatives answer the description "goods" at the

time of manufacture and thereafter there is no such

requirement; thereafter, as a matter of

construction, there are simply references back to

the opening words.

So, where goods have been manufactured,

provided the negatives are regarded as goods
manufactured, whether according to ordinary
concepts or by reason of the extended definition of
manufacture, paragraph (a) is answered. Then, (b)
says "and the goods". All that it is doing is
referring back to goods manufactured. It does not

require any other temporal requirement in respect

of answering that condition:

the goods were manufactured in whole or in

part out of materials supplied by the

customer.

Indeed, it raises no different temporal

consideration because it uses the word "were" and

refers back to the manufacturing process. Then it
goes on to say: 

the manufacturer of the goods -

does not require that that be answered at any time

other than that which has gone heretofore -

shall, for the purposes of this Act, be deemed

to have -

done something. He is deemed:

to have sold the goods to the customer.

Kodak(3) 78 7/4/92

It does not say he is deemed to have sold the goods

to the customer if they are delivered to the

customer as goods which answer the definition. The

sufficient requirements for the deeming provision

are that goods were manufactured and that they:

were manufactured in whole or in part out of

materials supplied by the customer -

and then the deeming is complete. The fallacy of

our friend's argument and the fallacy of the approach of His Honour Mr Justice Hill, with

respect, was that they have interpolated a third

requirement. They have interpolated a requirement

that the objects still answer the description of

goods at the time of delivery. They have construed
it as if it read: 

the manufacturer of the goods shall for the

purposes of this Act, be deemed to have sold

the goods to the customer at the time when the

goods -

as goods -

were delivered to the customer -

and, in our respectful submission, there is no

justification for that course.

DEANE J:  Why, on that argument, would not 17A apply, even

if you be right on your 17 argument, and they have

been applied to "own use"?

MR GZELL:  They do, but the answer to that, Your Honour, is

that a taxing point has been passed, so that when

you take -

DEANE J: Well, you say a taxing point has been passed, but

you might as well say the point which takes them

out of "goods" for the purposes of the Act is

comparable to a taxing point.

MR GZELL: Well, I put it slight differently, Your Honour.

Let us suppose that my primary argument is right,

the negatives are applied by the manufacturer to

own use when he shines the light through them.

17(1) then operates and takes the goods past the

taxing point of application to own use, and tax is

exigible at that point.

DEANE J: Well, you are putting it that way, but another way

of looking at it is that section 17, having

applied, they are no longer goods for the purposes

of the Act.

Kodak(3) 79 7/4/92
MR GZELL:  We would say that logically the application

precedes the 17A deeming sale because the 17A

deeming sale takes effect on delivery, so that

prior to delivery there has been an application to

own use, and section 17(1) is answered because one

of the taxing points is then crossed. Thereafter,

the negatives are delivered to the customer.

17A(l) says that is a deemed sale. Go back to 17:

but there can be no further exigibility in respect of the deemed sale because the taxing point having

been crossed, that is the end of the matter. As
York Motors pointed out, you have three

alternatives, but once one is crossed there is no

further operation for section 17.

DEANE J: Well, that answers my query in favour of yourself

by assuming that the reason one refers to a taxing
point being crossed is not that a taxing point

being crossed means that they are no longer goods

for the purposes of the Act. But if the reason the

taxing point being crossed is that that means they

cease to be goods for the purposes of the Act, your

argument on 17A would lead to it applying,

notwithstanding that the taxing point had been

passed, because you say it does not matter whether

or not they are goods at the stage when 17A

attaches.

MR GZELL:  I do not know whether I have quite got

Your Honour's proposition but certainly Your Honour

is right in saying to me that the way I have put it

is upon the supposition that it is the crossing of a

taxing point which takes the commodity or article

out of the denotation of goods. No, my friend tells

me it is the connotation of goods, at that stage.

MASON CJ:  We might adjourn, Mr Gzell, and you can give it

some thought.

DEANE J:  I think you have got to say the opposite.

MR GZELL: Connotation, perhaps.

MASON CJ:  We will resume at 10.15 tomorrow.

AT 4.19 PM THE MATTER WAS ADJOURNED

UNTIL WEDNESDAY, 8 APRIL 1992

Kodak(3) 80 7/4/92

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