Question: Roxanoca Land, a real estate developer, organized in the 1960s, bought several parcels of land

in Rio Tuba, Palawan during the 1960s. It has never registered as VAT liable since its sales during the
past years did not meet the mandatory liability for VAT. However, during the current year, due to
increased transactions, it became liable for the first time for VAT. Roxanoca Land invoked entitlement to
transitional input taxes on all its landholdings, but the same was disallowed because according to the
BIR, the purchase of these lands happened at a time when no VAT was imposed in the country, and that
no input VAT was actually paid on such lands. Was the action of the BIR proper? Decide
Roxanoca Land is entitled to transitional input VAT regardless of its prior non VAT registration
Roxanoca Land is entitled to transitional input VAT only if it can claim that it shouldered the burden of
the VAT during the prior years.
Roxanoca Land is not entitled to transitional input VAT as it never registered itself in the past as VAT
liable
Roxanoca Land is not entitled to transitional input VAT because when the purchase was made, the VAT
law was not yet in force.