BIR Ruling No. 119-82

April 15, 1982 BIR RULING NO. 119-82 024-g 000-00 119-82 Panay Railways, Incorporated Lapuz, Iloilo City Attention: Mr . Carlos C . Capague Assistant Corporate Secretary Gentlemen : This refers to your letter dated July 2, 1980, requesting exemption from the payment of all taxes except franchise tax. In reply, we regret to inform you that your request cannot be granted. It must be noted that notwithstanding that "in lieu provision" in Act No. 1497, you are now liable for the payment of income tax pursuant to Section 24(g) of the Tax Code, as amended. (Koronadal Electric Light & Power Co., Inc. vs. Commissioner of Internal Revenue, CTA Case No. 2600, June 26, 1979 and RCPI vs. Commissioner of Internal Revenue, CTA Case No. 2426, January 25, 1980). Moreover, you are also liable for the payment of compensating tax on your importation. (Meralco vs. Commissioner of Internal Revenue, G.R. Nos. L-29987 and L-23847, October 22, 1975). Please be guided accordingly. cdti Very truly yours, RUBEN B. ANCHETA Acting Commissioner