BIR Ruling [DA-056-02]

April 01, 2002 BIR RULING [DA-056-02] Center For Metro Manila Vendors Development, Inc. 176-178 Carlos Palanca St., Quiapo, Manila Attention: Col. Brigido P. Mesina Jr. MNSA Executive Director Gentlemen : This refers to your letter dated January 27, 2001 requesting for an opinion on the proper, legal, and/or financial meaning of the term "APPRAISED VALUE". It is your understanding that the appraised value of any government land subject to sale and/or lease is the value that comes out higher between the zonal value as determined by the BIR and the assessed value certified by the city/municipality where the property is located. It is likewise your opinion that the appraised value is not the ceiling price but rather the floor price for the lease of said property. Under Section 6(E) of the Tax Code of 1997, the Commissioner of Internal Revenue is authorized to determine the zonal values of real properties, but solely for the purpose of computing any internal revenue tax, which is not the issue in your situation. In reply, please be informed that the lease transaction of the Center for Metro Manila Vendors Development, Inc. is with the local government of the City of Manila. In this regard, this Office is not the appropriate agency to interpret the proper, legal, and/or financial meaning of the term "APPRAISED VALUE" since any Ruling that will be issued on the matter shall not bind the government unit concerned. Kindly address your query to the Bureau of Local Government Finance or the Department of Justice, which has the proper jurisdiction on this matter. Very truly yours, Commissioner of Internal Revenue By: (SGD.) EDMUNDO P. GUEVARA Deputy Commissioner Legal & Inspection Group