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Commissioner of Internal Revenue vs. Bicolandia Drug Corporation

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus BICOLANDIA DRUG CORPORATION (Formerly known as ELMAS DRUG CO.), Respondent.

G.R. No. 148083 | 2006-07-21

THIRD DIVISION

DECISION 

VELASCO, JR., J.: 

In cases of conflict between the law and the rules and regulations implementing the law, the law shall always prevail. Should Revenue Regulations deviate from the law they seek to implement, they will be struck down. 

The Facts 

In 1992, Republic Act No. 7432, otherwise known as "An Act to Maximize the Contribution of Senior Citizens to Nation Building, Grant Benefits and Special Privileges and For Other Purposes," granted senior citizens several privileges, one of which was obtaining a 20 percent discount from all establishments relative to the use of transportation services,...