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	GR No. 202789 2015-06-22	CIR v. PUREGOLD DUTY FREE VELASCO JR., J.
As respondent Puregold correctly points out, BIR Ruling 149-99 has not been reversed or overruled either by the CIR or the Courts. In fact, the tax incentives enjoyed by businesses within CSEZ as provided for in EO 80 were even upheld by the BIR through a succeeding ruling.[18]
	GR No. 195909 2012-09-26	CIR v. ST. LUKE’S MEDICAL CENTER CARPIO, J.
Charitable institutions, however, are not ipso facto entitled to a tax exemption. The requirements for a tax exemption are specified by the law granting it. The power of Congress to tax implies the power to exempt from tax. Congress can create tax exemptions, subject to the constitutional provision that "[n]o law granting any tax exemption shall be passed without the concurrence of a majority of all the Members of Congress."[43] The requirements for a tax exemption are strictly construed against the taxpayer[44] because an exemption restricts the collection of taxes necessary for the existence of the government.