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    <description>Memory cards are treated as IT products falling within specific concessional entries for recording media or computer peripherals, rather than a residuary tax entry, where they are capable of recording and storing data and no cogent technical evidence excludes them. A later prospective insertion specifically naming memory cards may support their IT-product character without retrospectively altering the entry. A classification consistently accepted over time cannot be reopened solely because of a departmental determination or change of opinion. Reassessment requires independent supporting material; quasi-judicial authorities are not bound by departmental determinations. Consequently, reassessment-based additional tax and interest demands were unsustainable.</description>
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