BIR Ruling No. 150-61

April 12, 1961 BIR RULING NO. 150-61 2nd Indorsement Respectfully returned to the Chief, Investigation Division, Bureau of Internal Revenue, Manila, the docket bearing on the internal revenue case of Chua Un Sian & Co., 739 Caballeros St., Manila, covering the years from 1955 to 1959. Pursuant to Section 11 of Republic Act No. 901, the power to "determine the scope and extent of the privileges granted" under said Act is lodged with the Secretary of Finance. Such being the case, in the determination of whether or not any activity or business of a taxpayer comes within the purview of the tax exemption granted to him it in accordance with Republic Act No. 901, the decision of the Secretary of Finance must necessarily prevail over that of this Office. Accordingly, and considering that by letter dated March 6, 1955 said official had already held that the business of the aforenamed company of manufacturing tin cans out of this plates supplied by its customers falls within the purview of its tax exemption, this Office is left with no other alternative than to follow said decision, notwithstanding our ruling (No. 652, s. 1959). cdpr (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue