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	GR No. 172394 2010-10-13	H. TAMBUNTING PAWNSHOP v. CIR BERSAMIN, J.
The aforequoted pronouncement in First Planters Pawnshop has been reiterated in Tambunting Pawnshop, Inc. v. Commissioner of Internal Revenue[12] and in TFS, Incorporated v. Commissioner of Internal Revenue,[13] thereby affirming the non- liability for VAT of pawnshops in taxable years 1996-2002 by virtue of the deferment of its imposition. Consequently, the VAT deficiency assessment and the surcharge served on Tambunting by the BIR lacked legal basis and must be canceled.