06-02-2019, 02:51 PM
Tax refunds are in the nature of tax exemptions. They are regarded as in derogation of sovereign authority and to be construed strictissimi jurisagainst the person or entity claiming the exemption.
The burden of proof is upon him who claims the exemption in his favor and he must be able to justify his claim by the clearest grant of organic or statute law (CIR vs. CA, GR No. 104151, March 10, 1995).
The burden of proof is upon him who claims the exemption in his favor and he must be able to justify his claim by the clearest grant of organic or statute law (CIR vs. CA, GR No. 104151, March 10, 1995).