This case has been cited 2 times or more.
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2013-07-29 |
BERSAMIN, J. |
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| Again, we affirm the foregoing holding of the CTA En Banc for the reasons therein stated. To reiterate, deductions for income tax purposes partake of the nature of tax exemptions and are strictly construed against the taxpayer, who must prove by convincing evidence that he is entitled to the deduction claimed.[27] Tambunting did not discharge its burden of substantiating its claim for deductions due to the inadequacy of its documentary support of its claim. Its reliance on withholding tax returns, cash vouchers, lessor's certifications, and the contracts of lease was futile because such documents had scant probative value. As the CTA En Banc succinctly put it, the law required Tambunting to support its claim for deductions with the corresponding official receipts issued by the service providers concerned. | |||||
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2010-09-08 |
ABAD, J. |
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| An agent is a person who binds himself to render some service or to do something in representation or on behalf of another, with the consent or authority of the latter.[26] The essence of an agency is the agent's ability to represent his principal and bring about business relations between the latter and third persons.[27] An agent's ultimate undertaking is to execute juridical acts that would create, modify or extinguish relations between his principal and third persons.[28] It is this power to affect the principal's contractual relations with third persons that differentiates the agent from a service contractor. | |||||