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Davao Gulf Lumber Corp. Vs. Commissioner Of Internal Revenue, et al. 293 SCRA 76

DAVAO GULF LUMBER CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE and COURT OF APPEALS, respondents.

G.R. No. 117359 | 1998-07-23

D E C I S I O N

PANGANIBAN, J:

Because taxes are the lifeblood of the nation, statutes that allow exemptions are construed strictly against the grantee and liberally in favor of the government. Otherwise stated, any exemption from the payment of a tax must be clearly stated in the language of the law; it cannot be merely implied therefrom.

Statement of the Case

This principium is applied by the Court in resolving this petition for review under Rule 45 of the Rules of Court, assailing the Decision 1 of Respondent Court of Appeals 2 in CA-GR SP No. 34581 dated September 26, 1994, which affirmed the June 21, 1994 Decision 3 of the Court of Tax...