Tax Imposed on Miranda's Refrigeration Service and Supply, 8 Martinez Street, Manila

January 17, 1958 BIR RULING NO. 037-58 The Regional Director BIR Regional District No. 3 Manila S i r : This refers to the internal revenue case of Miranda's Refrigeration Service and Supply, 8 Martinez Street, Manila. According to the agent who investigated this case, the taxpayer makes meat case, fruit case, meat-fruit case combination, and freezers. These articles are made with or without order from a customer who supplies the desired specifications as to kind, make and dimensions. Under these circumstances, the taxpayer is a manufacturer liable for the payment of the sales tax imposed in Section 185 of the National Internal Revenue Code. The sales tax shall be based on the gross selling price of the manufactured articles less the cost of tax-paid raw materials. However, inasmuch as the taxpayer was granted tax-exemption as a new and necessary industry, it is exempt from all internal revenue taxes directly payable by it in respect to said industry beginning June 20, 1953, in the case of fruit case, meat case and meat-fruit case combination and April 25, 1955, in the case of freezers. prcd Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue