The respondent argued that the colour coding of and addition of the materials to the packages did not change them in any substantial way and that those steps were part of the process of shipping the packages. She compared this case to Bam Packaging v. R. [2001] G.S.T.C. 76 where freight handling services that were provided by the taxpayer were found to be incidental to the transportation of goods and not to be further processing, transformation or alteration of the goods beyond what was reasonably necessary for their transportation. In Bam, the taxpayer's services included taking receipt of goods from clients; unloading and checking them; dismantling them as necessary; packing; recording, and weighing them, labelling the goods for approval by foreign customs agents transferring them into shipping containers and sealing the containers.
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