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	GR No. 187485 2013-10-08	CIR v. SAN ROQUE POWER CORPORATION CARPIO, J.
To justify the application of the doctrine of operative fact as an exemption, San Roque asserts that "the BIR and the CTA in actual practice did not observe and did not require refund seekers to comply with the 120+30 day periods."[4] This is glaring error because an administrative practice is neither a law nor an executive issuance. Moreover, in the present case, there is even no such administrative practice by the BIR as claimed by San Roque.