BIR Ruling No. 167-61

April 6, 1961 BIR RULING NO. 167-61 Mr. Alfredo Sandoval 2519 Anacleto, Sta. Cruz Manila S i r : Reference is made to your letter dated May 17, 1960, as supplemented by that dated June 8, 1960, requesting information whether or not your sales of fish are exempt from the 7% sales tax prescribed in Section 186 of the National Internal Revenue Code. cdti In answer thereto, I have the honor to inform you that upon investigation conducted by this Office, it was found that as fishing operator you sell part of your catch as fresh fish while the rest are salted and sold as "buro"; that fresh fish is salted into "buro" for the purpose of preservation; and that the process involved therein does not constitute manufacturing. Such being the case, this Office is of the opinion and so holds that your sales of fresh fish, as well as "buro", are exempt from the 7% sales tax, pursuant to Section 188(b) of the Tax Code. A copy of this letter has, on even date, been furnished the Provincial Revenue Officer of Palawan for his information. Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue