This case has been cited 1 times or more.
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2007-08-03 |
QUISUMBING, J. |
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| Thus, on the first issue, we rule against respondent's contention. Entrenched in our jurisprudence is the principle that tax refunds are in the nature of tax exemptions which are construed strictissimi juris against the taxpayer and liberally in favor of the government. As tax refunds involve a return of revenue from the government, the claimant must show indubitably the specific provision of law from which her right arises; it cannot be allowed to exist upon a mere vague implication or inference[17] nor can it be extended beyond the ordinary and reasonable intendment of the language actually used by the legislature in granting the refund.[18] To repeat, strict compliance with the conditions imposed for the return of revenue collected is a doctrine consistently applied in this jurisdiction.[19] | |||||