Costs of Installation of Manufactured Window Frames Form Part of the Sales Tax

July 7, 1959 BIR RULING NO. 321-59 Tax Service of the Philippines Floor 3, MRS Building Plaza Cervantes, Manila Gentlemen : Reference is made to your letter dated July 7, 1959 requesting the reconsideration of B.I.R. Ruling No. 270 dated April 15, 1959 in respect of that portion thereof which provides that the costs of installation of manufactured window frames form part of the sales tax. As basis for your request, you invoke the decision of the Supreme Court in the cases entitled "Collector vs. Eternit Corporation", G.R. No. L-11891, and "Eternit Corporation vs. Collector", G.R. No. L-11913, both decided on April 29, 1959. We read very carefully the aforesaid cases and we agree with you that the doctrine enunciated therein indeed considers installation as distinct and separate from manufacture. Such being the case, our Ruling No. 270, series of 1959, is accordingly modified. The manufacturer of window frames referred to in your letter of inquiry should therefore, pay the 7% sales tax on his sales of the manufactured frames and the 3% contractor's tax on the installation thereof. It is of course understood that he should also provide himself with distinct privilege tax-receipts as manufacturer and contractor. aisadc Very truly yours, (SGD.) JOSE ARAAS Commissioner of Internal Revenue