Rulings of first impression

Rulings of first impression by an assistant commissioner is not valid, as this contravenes the provision of Section 7 of the NIRC, which states that the power to issue rulings of first impression or to reverse, revoke or modify any existing ruling of the Bureau shall not be delegated. (Metropacific Corporation vs. Commissioner of Internal Revenue, CTA Case No. 83138, June 11, 2014)