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Tambunting Pawnshop vs. CIR

H. TAMBUNTING PAWNSHOP, INC.,PETITIONER,-VERSUS- COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

CTA Case No. 6915 | 2004-04-11

 
PALANCA-ENRIQUEZ, J.
 
Pursuant to Section 105 of the National Internal Revenue Code (hereafter “NIRC”) of 1997, as amended, any person who, in the course of trade or business, sells, barters, exchanges, leases goods or properties, renders services, and any person who imports goods shall be subject to the value-added tax (VAT) imposed in Sections 106 to 108 of this Code.

Are pawnshops engaged in the sale or exchange of services, and thus liable to pay Value-Added Tax (hereafter “VAT”) thereon? 
 
THE CASE

This issue is again before Us in this Petition for Review filed by H....