Tax Liability of a Carpentry Shop Exclusively for the Manufacture of Radio Cabinets

July 26, 1960 BIR RULING NO. 321-60 Messrs. N.C. Fernandez & Sons 497 Calbayog St. Mandaluyong Rizal Gentlemen : Reference is made to your undated letter, requesting information on whether or not you are subject to the 7% sales tax of the 3% contractor's tax. You manifested that you are operating a carpentry shop exclusively for the manufacture of radio cabinets. Such radio cabinets are manufactured only upon specific orders from radio manufacturers and in accordance with wood to be used. You do not manufacture for your account radio cabinets for indiscriminate sale to the public. In reply thereto, I have the honor to inform you that, on the basis of your representation, you are a contractor subject to the fixed annual tax of P20.00 and the percentage tax of 3% on gross receipts prescribed by Section 182 and 191 of the Tax Code. The persons who place orders with you for the manufacture of radio cabinets are the manufacturers subject to the fixed and percentage taxes prescribed by Sections 182 and 186 of the Tax Code. This Office however, may alter, modify or revoke this ruling if after investigation, the facts are different from that prescribed by you. cdtech Very truly yours, (SGD.) MELECIO R. DOMINGO Commissioner of Internal Revenue