BIR Ruling No. 108-83

June 16, 1983 BIR RULING NO. 108-83 Gentlemen : This refers to our letter-ruling dated December 5, 1973 to Messrs. Joaquin Cunanan & Co., holding that the processes employed by you in blending and/or mixing of imported bulk materials into milk products namely, Alacta Powder, Enfamil Powder, Sustagen Powder and Strive Choco Drink does not constitute manufacturing. In connection therewith, I have the honor to inform you that after a re-study of the aforementioned ruling, this Office finds that said milk products are manufactured products. Accordingly, your sales thereof are subject to the 5% sales tax prescribed by Section 201(a) of the National Internal Revenue Code, as amended. It may be stated that under Section 187(x) of the Tax Code, there is manufacturing if raw materials or manufactured or partially manufactured products are combined with other materials or products of the same or to different kinds in such manner that the finished product can be put to a special use or uses to which such raw material or manufactured or partially manufactured products in their original condition could not have been put. aisadc This revokes our ruling dated December 5, 1973. Very truly yours, (SGD.) RUBEN B. ANCHETA Acting Commissioner Bureau of Internal Revenue