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COLLECTOR OF INTERNAL REVENUE v. LA TONDENA INC.

This case has been cited 1 times or more.

2001-12-18
PUNO, J.
There is nothing in E.O. No. 64 that provides that it should retroact to the date of effectivity of E.O. No. 41, the original issuance.  Neither is it necessarily implied from E.O. No. 64 that it or any of its provisions should apply retroactively.  Executive Order No. 64 is a substantive amendment of E.O. No. 41. It does not merely change provisions in E.O. No. 41. It supplements the original act by adding other taxes not covered in the first.[12] It has been held that where a statute amending a tax law is silent as to whether it operates retroactively, the amendment will not be given a retroactive effect so as to subject to tax past transactions not subject to tax under the original act.[13] In an amendatory act, every case of doubt must be resolved against its retroactive effect.[14]