BIR Ruling No. 009-61

January 9, 1961 BIR RULING NO. 009-61 This has reference to the attached memorandum dated . . ., of Supervising Tobacco Inspector Demetrio D. Velasco, requesting opinion on the question of whether or not agents of the Philippine Tobacco Administration (PTA) may inspect or examine the internal revenue books and other records of wholesale leaf tobacco dealers, such as the L-3 registers, official guia books, etc. cdta While Sections 157, 158 and 159 of the Tax Code require the keeping and preservation of records and invoices by wholesale dealers of specific articles, subject to inspection at any time by internal revenue officers; on the other hand, Republic Act No. 1135, creating the PTA, as amended by Republic Act No. 2233, is silent as to the power or authority of PTA agents to inspect or examine said books and records. However, considering that there are functions which the law has imposed upon the PTA in the performance of which the necessity to inspect or examine the books and records in question may arise, this Office is of the opinion and so holds that in cases of necessity therefor those books and records may be inspected or examined by PTA agents, provided that in so doing they do not usurp the authority of the Bureau of Internal Revenue. Please advise all concerned of the above ruling. cdti