BPI Leasing Corporation v. CA
BPI Leasing Corporation v. CA
BPI Leasing Corporation v. CA
[2]
There is no indication that the revenue regulation may
operate retroactively.
Rule: The principle is well entrenched that statutes, including
administrative rules and regulations, operate prospectively
only, unless the legislative intent to the contrary is manifest
by express terms or by necessary implication.
Rule: It is also apt to add that tax refunds are in the nature
of tax exemptions. As such, these are regarded as in
derogation of sovereign authority and are to be strictly
construed against the person or entity claiming the
exemption.