dissenting.
I dissent.
The majority has concluded in this case that an embroidered insignia merely “effects an aesthetic change” to a ready-made garment, maj. op. at 936, and therefore, that appellant, The Kimberton Company, does not qualify for the manufacturing exemption under the Capital Stock Tax Act, 72 P.S. § 7602. I disagree.
It has long been the law of this Commonwealth that a taxpayer who engages in printing or lithographing is exempt from the capital stock tax as a manufacturing entity. See, e.g., Commonwealth v. William Mann Co., 150 Pa. 64, 24 A. 601 (1892). A printer begins with paper and ends with paper. In light of the majority’s ruling in the instant case, the ink which is applied to paper during the printing *244process would also merely “effect an aesthetic change.” This is nonsense.
By the application of skill and labor to material, appellant substantially changes indistinguishable spools of thread into distinctive insignia based upon the designs submitted by appellant’s customers. The attachment of the insignia to a ready-made shirt substantially changes that shirt in the same way that the application of ink to blank paper substantially changes that paper by making it a different and more valuable commodity.1 What is the difference if one prints with thread on cloth or with ink on paper.
The contrary conclusion reached by the majority contravenes the purpose of the legislature in exempting manufacturers from the capital stock tax. See Golden Triangle Broadcasting, Inc. v. City of Pittsburgh, 483 Pa. 525, 397 A.2d 1147 (1979) (Larsen, J., dissenting) (legislative limits on taxation of manufacturers is intended to encourage the growth of manufacturing in this Commonwealth).
Accordingly, I would reverse the order of Commonwealth Court and remand for the recalculation of appellant’s capital stock tax refund for the years 1982 and 1983.
PAPADAKOS, J., joins in this dissenting opinion.. In the words of the immortal Shakespeare: “the apparel oft proclaims the man.” Hamlet, I, iii, 65.