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SURIGAO CONSOLIDATED MINING CO. v. COLLECTOR OF INTERNAL REVENUE

This case has been cited 1 times or more.

2005-02-11
PANGANIBAN, J.
Tax refunds are in the nature of such exemptions.[105] Accordingly, the claimants of those refunds bear the burden of proving the factual basis of their claims;[106] and of showing, by words too plain to be mistaken, that the legislature intended to exempt them.[107] In the present case, all the cited legal provisions are teeming with life with respect to the grant of tax exemptions too vivid to pass unnoticed. In addition, respondent easily meets the challenge.