Thus, the statutory test for determining whether the industrial processing exemption applies is whether the petitioner performs services which transform, alter or modify the property so as to place it in a different form, composition or character. We agree with the MTT that here petitioner was unable to meet this test. In reviewing decisions of the MTT, this Court is limited to determining whether the tribunal's findings are supported by competent, material, and substantial evidence. In the absence of fraud, this Court reviews whether the MTT made an error of law or adopted an incorrect legal principle. Additionally, petitioner asserts that the MTT incorrectly interpreted the use tax act.
Statutory interpretation is a question of law subject to de novo review.
Petitioner contends that the MTT made an error of law when it determined that petitioner did not meet the legislative intent of the statutory requirements for the industrial processing exemption. Prior to the passage of 1970 PA 15, the industrial processing exemption could be used by persons who provided a service essential to the industrial process of a manufacturer or producer and processed a commodity to condition it for later sale. Beckman, supra at 344 . While it is correct that changes in statutory language are presumed to reflect a change in meaning, Beckman, supra at 345, this Court has also recognized that changes in statutory language may reflect an attempt to clarify the meaning of a provision rather than change it. Accordingly, we find no errors of law on the part of the MTT and conclude that the factual findings are supported by competent, material, and substantial evidence.