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	GR NOS. 134587 & 134588 2005-08-08	CIR v. BENGUET CORPORATION TINGA, J.
Manila Mining Corporation v. Commissioner of Internal Revenue,[23] in which the Court of Appeals held[24] that BIR VAT Ruling No. 008-92 cannot be given retroactive effect. Lastly, the Court of Appeals observed that R.A. 7716, the "The New Expanded VAT Law," reveals the intent of the lawmakers with regard to the treatment of sale of gold to the Central Bank since the amended version therein of Sec. 100 of the NIRC expressly provides that the sale of gold to the Bangko Sentral ng Pilipinas is an export sale subject to 0% VAT rate. The appellate court thus allowed respondent's claims, decreeing in its dispositive portion, viz:
	GR Nos. 134587 & 134588 2005-07-08	CIR v. BENGUET CORPORATION TINGA, J.
Manila Mining Corporation v. Commissioner of Internal Revenue,[23] in which the Court of Appeals held[24] that BIR VAT Ruling No. 008-92 cannot be given retroactive effect. Lastly, the Court of Appeals observed that R.A. 7716, the "The New Expanded VAT Law," reveals the intent of the lawmakers with regard to the treatment of sale of gold to the Central Bank since the amended version therein of Sec. 100 of the NIRC expressly provides that the sale of gold to the Bangko Sentral ng Pilipinas is an export sale subject to 0% VAT rate. The appellate court thus allowed respondent's claims, decreeing in its dispositive portion, viz: