The  21st  section  of  the  Act  of  June  1,  1889,  P.  L.  420,  super-
seding the  20th  section  of  the  Act  of  June  30,  1885,  supra,  pro-
vided, inter  alia,  as  follows :

.  .  .  And  provided  further,  that  the  provisions  of  this  sec-
tion shall  not  apply  to  the  taxation  of  the  capital  stock  of  corpo-
rations, limited  partnership  and  joint  stock  associations  organised
exclusively  for  manufacturing  purposes,  and  actually  carrying  on
manufacturing  within  the  state,  except  companies  engaged  in  the
brewing  or  distilling  of  spirits  or  malt  liquors,  and  such  as  en-
joy "and  exercise  the  right  of  eminent  domain.
This  provision  made  artificial  gas  companies  entitled  to  ex-
emption from  taxation  with  other  non-excepted  manufacturing
companies,^  and  omitted  from  the  excepted  corporations  those
engaged  in  the  manufacture  of  vinous'  liquors.
The  above  Act  of  1889  exempted  from  taxation  only  such  man-
ufacturing corporations  as  were  "organized  exclusively  for  man-
ufacturing purposes,"  and  it  was  held  in  numerous  cases  that
corporations  incorporated  with  the  right  to  carry  on  any  other
business  than  manufacturing,  were  not  within  the  meaning  of  the
exemption,  although  they  did  not,  in  fact,  carry  on  such  other
business.*

A  corporation  incorporated  for  the  purpose  of  carrying  on  an
exclusively  manufacturing  business,  however,  was  held  to  be
exclusively  manufacturing  within  the  meaning  of  the  act,  not-

*Com.   V.    Lackawanna    Iron    &  Bridge   Co.,   156   Pa.   500    (1893);

Coal  Co.,  129  Pa.  346  (1889).  Com.    v.    Pittsburgh    Bridge    Co.,

'Com.     V.     Mahoning     Rolling  156     Pa.     507     (1893);     Com.     v.
Mill   Co.,  129  Pa.  360   (1889).  Pottsville,    I.    &    S.    Co.    157    Pa.
