Practice question
A tax statute clearly exempts a precisely defined qualifying transaction, and the claimant indisputably meets every condition. The collector argues strict construction means the exemption may be denied anyway. Which is correct?
- Strict construction authorizes arbitrary denial
- A clear applicable exemption must be given effect; strict construction is not authority to nullify the legislature’s grant
- Every exemption is void
- Only the collector’s revenue quota controls
- The claimant must prove a different law grants the same exemption twice
Legal references
- https://lawphil.net/judjuris/juri1998/jul1998/gr_117359_1998.html — Davao Gulf Lumber v. CIR, G.R. No. 117359, July 23, 1998, main opinion
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