This case has been cited 1 times or more.
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2006-05-03 |
YNARES-SANTIAGO, J. |
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| In the instant case, there is no law specifically and expressly exempting pledges entered into by pawnshops from the payment of DST. Section 199[17] of the NIRC enumerated certain documents which are not subject to stamp tax; but a pawnshop ticket is not one of them. Hence, petitioner's nebulous claim that it is not subject to DST is without merit. It cannot be over-emphasized that tax exemption represents a loss of revenue to the government and must, therefore, not rest on vague inference.[18] Exemption from taxation is never presumed. For tax exemption to be recognized, the grant must be clear and express; it cannot be made to rest on doubtful implications.[19] | |||||