Section 61
SEC. 61. A new section is hereby inserted between Sections three hundred and thirty-eight and three hundred and thirty-nine, to be known as Section three hundred and thirty-eight A, which shall read as follows: "SEC. 338-A. Non-retroactivity of rulings.—Any revocation, modification, or reversal of any of the rules and regulations promulgated in accordance with the preceding section or any of the rulings or circulars promulgated by the Commissioner of Internal Revenue shall not be given retroactive application if the revocation, modification, or reversal will be prejudicial to the taxpayers except in the following cases: (a) where the taxpayers deliberately misstates or omits material facts from his return or in any document required of him by the Bureau of Internal Revenue; (b) where the1 facts subsequently gathered by the Bureau of Internal Revenue are materially different from the facts on which the ruling is based; or (c) where the taxpayer acted in bad faith."