BIR Ruling No. 201-15

June 10, 2015 BIR RULING NO. 201-15 Revenue Bulletin No. 01-03; BIR Ruling No. 033-12 Atty. Hector Reuben D. Feliciano 1614 San Lazaro St., Sta. Cruz, Manila Dear Atty. Feliciano, This refers to your letter dated October 9, 2014 requesting, issuance of a ruling on the legality of collecting 3% percentage tax from 4F LUCKY PICK CORNER, INC. by RDO No. 31 with reference to its assessment dated August 15, 2014. In reply, please be informed that requests for rulings on issues covered by an on-going assessment or audit by the Revenue District Offices of the Bureau is a "No Ruling Area" under Section 2 (r) of Revenue Bulletin No. 01-03 and which this Office is not constrained to dispense a ruling therefor. SECTION 2. List of No-Ruling Areas . The following shall hereby be construed and identified as "No-Ruling Areas": r) Issue/s or transactions involving directly or indirectly the same taxpayer/s which is/are the subject of an investigation, on-going audit, administrative protest, claim for refund or issuance of tax credit certificate, collection proceedings, or a judicial appeal subject to Section 3 hereunder. Accordingly, the taxpayer must submit and include the following statement in the request for ruling: "The issue/s or transaction subject of the request is not under investigation, on-going audit, administrative protest, claim for refund or issuance of a tax credit certificate, collection proceedings, or a judicial appeal of the taxpayer/s involved"; cAaDHT In view of the fact that there is an assessment issued by RDO 31 to 4F LUCKY PICK CORNER, INC. covering the same taxpayer and tax type, this Office declines to issue a ruling on the issue raised. Very truly yours, (SGD.) KIM S. JACINTO-HENARES Commissioner of Internal Revenue