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CIR v. VISAYAN ELECTRIC COMPANY

This case has been cited 1 times or more.

2008-09-16
NACHURA, J.
Tax exemptions are never presumed and are strictly construed against the taxpayer and liberally in favor of the taxing authority.[22] They can only be given force when the grant is clear and categorical.[23] The surrender of the power to tax, when claimed, must be clearly shown by a language that will admit of no reasonable construction consistent with the reservation of the power. If the intention of the legislature is open to doubt, then the intention of the legislature must be resolved in favor of the State.[24]