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Tax classification of GRD Powder and GRD Mix depends on the goods' identity and physical form at the time of supply, not on their subsequent use after mixing with milk or water. Strict construction of taxing statutes requires classification at the taxable event; a purchaser's use cannot convert a powder or biscuit-form product into a beverage. The entry for non-alcoholic drinks and beverages, read ejusdem generis with syrups, cordials, distilled juices, ark and essences, covers liquids or liquid preparations. GRD Powder and GRD Mix therefore fall under the residuary entry rather than the specific entry for non-alcoholic drinks and beverages.
Tax classification of GRD Powder and GRD Mix depends on the goods' identity and physical form at the time of supply, not on their subsequent use after mixing with milk or water. Strict construction of taxing statutes requires classification at the taxable event; a purchaser's use cannot convert a powder or biscuit-form product into a beverage. The entry for non-alcoholic drinks and beverages, read ejusdem generis with syrups, cordials, distilled juices, ark and essences, covers liquids or liquid preparations. GRD Powder and GRD Mix therefore fall under the residuary entry rather than the specific entry for non-alcoholic drinks and beverages.
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