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1 Rollo, pp. 31-55.

2 Second Division, composed of J. Ramon Mabutas Jr., ponente; and JJ Emeterio S. Cui, chairman, and Hilarion L. Aquino, member, both concurring.

3 Assailed Decision, p. 25; rollo, p. 55.

4 Petition for Review, p. 17; rollo, p. 26.

5 Assailed Decision, pp. 1-4; rollo, pp. 31-34 (citations omitted, parentheses in original).

6 Assailed Decision, p. 5; rollo, p. 35.

7 This case was deemed submitted for resolution on August 23, 1999, upon receipt by this Court of the Memorandum for the respondent; petitioners Memorandum was received on August 20, 1999.

8 Memorandum for Petitioner, pp. 11-12; rollo, pp. 169-170.

9 Joint Stipulation of Facts, p. 1; rollo, p. 58.

10 150 SCRA 133, 137, May 21, 1987, per Yap, J.

11 Sec. 3, Revenue Memo Circular No. 6-88.

12 Sec. 107 (a), National Internal Revenue Code.

13 Assailed Decision, p. 10; rollo, p. 40.

14 It provides that zero-rating applies to [t]he sale of raw materials or packaging materials to an export-oriented enterprise whose export sales exceed 70% of the total annual production. Any enterprise whose export sales exceed 70% of the total annual production of the preceding taxable year shall be considered an export-oriented enterprise upon accreditation as such under the provisions of the Export Development Act (Republic Act No. 7844) and its implementing rules and regulations.

15 Sec. 108, National Internal Revenue Code.

16 Sec. 21, Revenue Regulation 5-87.

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