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repealed by the deletion of PAGCOR as a tax – exempt entity under NIRC. The petitionerbelieved that the CIR proceeded without or in excess of its power, or with grave abuse ofdiscretion amounting to lack or excess of jurisdiction. The petitioner also asserted that the issuedprovision would affect the industry seeking welfare for the government and its people. To justifyits direct recourse before the Court, the petitioner then submitted justifications. The petitionercontend that even though the CIR has the jurisdiction “to interpret provisions of tax lawsthrough administrative issuances,” they cannot, however, “issue administrative rulings orcirculars not consistent with the law sought to be applied since administrative issuances mustnot override, supplant or modify the law, but must remain consistent with the law they intend tocarry out.” The respondent countered that no grave abuse of discretion was present on theissuance as it did not alter, modify, or amend its intent and meaning. The issue of the case is whether there was grave abuse of discretion in the issuance“subjecting the contractees and licensees of PAGCOR to income tax,” and whether the provisionwas valid or constitutional on its part.The court ruled, in accordance to their earlier decision that the petitioners income in itsgaming operations is subject to the 5% franchise tax only. Income from other related services isthe one subject to corporate income tax. Also, they maintained that a special law shall prevailover a general law. The court also concludes that CIR committed grave abuse of discretion whenit subjected “both incomes from gaming operations and other related services to corporateincome tax and 5% franchise tax”without due process, which has then generated added burdenupon PAGCOR. The petition was granted in the end which ordered the BIR “to cease and desistfrom implementing Revenue Memorandum Circular No. 33-2013 insofar as it imposes corporateincome tax on petitioners” income in its gaming operations.