This case has been cited 2 times or more.
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2015-07-01 |
MENDOZA, J. |
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| As it has been said, time and again, that claims for tax refunds are in the nature of tax exemptions which result in loss of revenue for the government. Upon the person claiming an exemption from tax payments rests the burden of justifying the exemption by words too plain to be mistaken and too categorical to be misinterpreted; it is never presumed nor be allowed solely on the ground of equity.[23] In addition, one who claims that he is entitled to a tax refund must not only claim that the transaction subject of tax is clearly and unequivocally not subject to tax - the amount of the claim must still be proven in the normal course,[24] in accordance with the prescribed rules on evidence. | |||||