Failure to Submit Loose-Leaf Invoices on Time

August 18, 1960 BIR RULING NO. 351-60 Chuidian Law Office P. O. Box 522 M a n i l a Gentlemen : In answer to your letter of the 3rd instant, I have the honor to inform you that, as in the case of loose-leaf invoice (BIR Ruling No. 446, s. 1959), the requirement imposed upon persons or corporations authorized to use loose-leaf books of accounts to submit within a certain period a sworn statement certifying to the number of pages used during a given period is neither a provision of the Tax Code nor a regulation of the Department of Finance issued in conformity therewith. Accordingly, failure to submit such statement on time does not constitute a violation of any internal revenue law or regulation. As a corollary, it may be stated that no compromise penalty can be imposed for said failure, it not giving rise to any penal liability either under section 352 of the Tax Code or any other section thereof. However, as in the case also of loose-leaf invoices, repetition of such failure will constrain this Office to revoke the authority granted to use loose-leaf books of accounts. LLjur Very truly yours, MELECIO R. DOMINGO Commissioner of Internal Revenue