Refund of Jilson Shirt Factory and Suan Bi Shirt Factory on the Cost of Raw Materials

January 9, 1958 BIR RULING NO. 020-58 Mr. S. Ferrer Attorney-at-Law Room 311 Globe Theatre Bldg. Raon, Quezon City Manila S i r : In reply to your request for refund of the amounts of P34,225.86 and P4,267.65 to your clients, Jilson Shirt Factory and Suan Bi Shirt Factory, respectively, I have the honor to inform you that following the decisions in BTA Case No. 187 entitled "Rufina & Company vs. David" and CTA Case No. 14, entitled "Ngo Siek vs. Collector of Internal Revenue" this Office ruled that, effective November 1, 1955 the cost of raw materials purchased from tax-exempt industries and used in the manufacture of articles was not deductible from the gross selling price of the manufactured products. It appearing that the taxes sought to be refunded were paid on raw materials purchased from tax-exempt industries and used in the manufacture of articles for the period beginning November 1, 1955 to June 21, 1957, I regret to inform you that your request cannot be granted. LLjur Very truly yours, (SGD.) JOSE ARAAS Collector of Internal Revenue