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The Commissioner of Internal Revenue assessed deficiency income taxes against the British Overseas Airways Corporation (BOAC) for revenue derived from ticket sales in the Philippines, even though BOAC had no landing rights in the Philippines. BOAC maintained a sales agent in the Philippines to sell tickets. The Court held that the source of the income was the Philippines, as the ticket sales activity occurred in the Philippines and payments were made in Philippine currency. Therefore, the revenue was subjec

Author

Agie Marquez

Language

EN