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Commissioner of Customs vs Philippine Phosphate Fertilizer Corp

COMMISSIONER OF CUSTOMS, Petitioner, versus PHILIPPINE PHOSPHATE FERTILIZER CORPORATION, Respondent.

G.R. No. 144440 | 2004-09-01

D E C I S I O N


Tinga, J.:

The financial planners of the State are often confounded by the precarious balance between the need to provide a conducive investment climate and the need to enhance revenue collections. In the present Petition for Review, the Court is called upon to interpret the provisions of a law designed to benefit investors with tax exemptions. Tax exemptions are generally construed strictly against the taxpayer; yet, when the purported ambiguities in the law are more imagined than real, there should be no hesitation to rule for the taxpayer.

The factual backdrop of the case is uncomplicated.

Respondent Philippine...