Commissioner of Internal Revenue vs. Engineering Equipment and Supply Company
Commissioner of Internal Revenue vs. Engineering Equipment and Supply Company
Commissioner of Internal Revenue vs. Engineering Equipment and Supply Company
Engineering Equipment and Supply Co. (Engineering for short), a domestic corporation, is
an engineering and machinery firm. As operator of an integrated engineering shop, it is
engaged, among others, in the design and installation of central type air conditioning system,
pumping plants and steel fabrications.
One Juan de la Cruz, wrote the then Collector, now Commissioner, of Internal Revenue
denouncing Engineering for tax evasion by misdeclaring its imported articles and failing to
pay the correct percentage taxes due thereon in connivance with its foreign suppliers.
ISSUE:
Whether or not design and installation of central type air-conditioning system is a sale or a
piece of work.
RULING: