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December 22, 2009BIR RULING [NSNP-(S30H-135) 807-09]Sec. 4 (3) Art. XIV, 1987 Constitution; ENPS-057-2007Imperial Learning Center, Inc.Block 8, Lots 23, 24 & 34Block 15, Lots 27, 28 & 29Buklod Bahayan, Barangay TartariaSilang, CaviteAttention: Ms. Nenita G. YloDirectorGentlemen :This refers to your letter dated May 26, 2009, which was referred to this Office by Revenue Region No. 9, San Pablo City, by way of 2nd Indorsement dated September 2, 2009, requesting for tax exemption pursuant to paragraph 3, Section 4 Article XIV of the 1987 Constitution. Documentary evidence submitted disclosed that the IMPERIAL LEARNING CENTER, INC. is a non-stock, non-profit educational institution duly registered with the Securities and Exchange Commission (SEC) under SEC Reg. No. 12192 dated August 15, 2001 and with Government Recognition No. 008, series of 2008.In reply, please be informed that paragraph 3, Section 4, Article XIV of the 1987 Constitution provides, viz.:"(3) All revenues and assets of non-stock, non-profit educational institutions used actually, directly and exclusively for educational purposes shall be exempt from taxes and duties. . . ."The exemption under Section 4...