13. CIR vs. CA, Central Vegetable Mfg. _ CTA.docx - CIR vs...

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CIR vs. CA, Central Vegetable Mfg. & CTA, GR No. 107135, 23 Feb. 1999 -13 DOCTRINE: It is a basic rule of interpretation that words and phrases used in the statute, in the absence of a clear legislative intent to the contrary, should be given their plain, ordinary and common usage or meaning. FACTS: CENTRAL VEGETABLE MANUFACTURING CO. ( CENVOCO) is a manufacturer of edible oil and coconut or coprameal cake and other coconut related oil subject to the miller's tax of 3%. It also manufactures lard, detergent and laundry soap subject to the sales tax of 10%. Petitioner purchased a specified number of containers and packaging materials for its edible oil from its suppliers and paid the sales tax due thereon. After an investigation conducted by CIR's Revenue Examiner, an assessment notice was issued against petitioner for deficiency miller's tax in the total amount of P1,575,514.70. CENVOCO filed with respondent CIR a letter requesting for reconsideration of the above deficiency miller's tax assessments, contending that the final provision of Section 168 of the Tax Code does not a apply to sales tax paid on containers and packaging materials, hence, the amount paid therefor should have been credited against the miller's tax assessed against it.

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