Celestino Co and Company vs Collector of Internal RevenueGR No. L-8506August 31, 1956

Facts:1) Celestino Co is the Owner of Oriental Sash factory, manufacturer of sash, window and

door. It has been paying its taxes as manufacturer at 7% of gross receipts2) It is claiming that it’s tax should only be at 3% because it is a contractor, evidenced by

the 3) The Court of Tax Appelas denied the claim.

Issue:Is Oriental Sash factory a manufacturer or contractor?Held: Oriental Sash of a manufacturer because it habitually makes sash, windows and doors, the special orders made by the customers does not divest the company of its character as a manufacturer.