(NAR) VOL. III NO. 3 / JULY - SEPTEMBER 1992
"June 26, 1992All concerned are hereby enjoined to give this Circular as wide a publicity as possible.MEMORANDUM FOR : The Commissioner
"This refers to the request to include meat and bone meal as VAT-exempt ingredients of animal feeds. The pertinent provision of Section 103 of the Tax Code is as follows:
(c) Sale or importation of fertilizers, pesticides and herbicides; chemicals for the formulation of pesticides; seeds, seedlings and fingerlings; fish, animal and poultry feeds/and soya beans and fish meals (underlining supplied).
"It is alleged that soya beans and fish meals are tax-exempt ingredients of animal feeds, so that meat and bone meals, being ingredients, should also be tax-exempt. I do not subscribe to such a view, dura lex sed lex. When the law is clear, no interpretation is needed (Ablan, Sr. vs. Madarang, G.R. No. L-32963, September 30, 1971).
"VAT Ruling Nos. 021-90 dated January 20, 1990 and 244-90 dated December 28, 1990, limiting the tax-exempt ingredients only to fish meal and soya beans should be maintained.
"Respectively submitted:(SGD.) REYNOSO B. FLOREZA
Assistant Commissioner
Legal Service