BIR Ruling [DA-034-01]

March 14, 2001 BIR RULING [DA-034-01] Sec. 90 (C) Vera Bookkeeping & Tax Services 2040-A Tomas Mapua, Sta. Cruz, Manila Attention: Ms . Sonia T . de Vera M a d a m : This refers to your letters dated October 2 and 18, 1999 addressed to Hon. Edgardo B. Espiritu, putting at issue the correctness of BIR Ruling Nos. 113-98 dated July 23, 1998, DA-350-99 dated June 16, 1999, DA-492-99 dated August 31, 1999 and DA-489-99 dated August 26, 1999 which rulings are interpretations by the Commissioner of Internal Revenue (CIR) of the provisions of the Tax Code of 1997. Under Section 4 of the Tax Code of 1997, the power to interpret the provisions of the Tax Code of 1997 and other tax laws shall be under the exclusive and original jurisdiction of the CIR. The interpretation by the CIR has administrative finality unless revoked or altered by the Secretary of Finance. This interpretation by the CIR is entitled to great weight and respect even by the Courts (Nestle Philippines, Inc. vs. Court of Appeals 203 SCRA 504, Nasiad Lozada vs. CTA 62 SCRA 208, CIR vs. Ayala Securities Corp. and CTA 70 SCRA 204). We regret to inform you that you are not entitled to any reward because under Section 282 (A) of the Tax Code of 1997, to be entitled to a reward the informer must provide BIR with definitive and sworn information not yet in the possession of the BIR. The facts you have recited in your letters are already known to the BIR and therefore did not qualify you to any reward. We hope the above explanations is sufficient answer to your letters. Very truly yours, (SGD.) MILAGROS V. REGALADO Acting Assistant Commissioner Legal Service