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ASTURIAS SUGAR CENTRAL v. COMMISSIONER OF CUSTOMS

This case has been cited 1 times or more.

2015-07-22
LEONEN, J.
The provision of Section 72 of the 1977 National Internal Revenue Code (Section 79 of the 1997 National Internal Revenue Code) regarding withholding on wages must be read and construed in harmony with Section 29(j) of the 1977 National Internal Revenue Code (Section 34(K) of the 1997 National Internal Revenue Code) on deductions from gross income. This is in accordance with the rule on statutory construction that an interpretation is to be sought which gives effect to the whole of the statute, such that every part is made effective, harmonious, and sensible,[97] if possible, and not defeated nor rendered insignificant, meaningless, and nugatory.[98] If we go by the theory of petitioner ING Bank, then the condition imposed by Section 29(j) would have been rendered nugatory, or we would in effect have created an exception to this mandatory requirement when there was none in the law.