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Insular Lumber Co. vs. CTA, 104 SCRA 710

INSULAR LUMBER COMPANY, petitioner, vs. COURT OF TAX APPEALS and COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. No. L-31057 | 1981-05-29

D E C I S I O N

DE CASTRO, J:

These two (2) cases are appeals by way of certiorari from the decision dated July 31, 1969 of the Court of Tax Appeals ordering the Commissioner of Internal Revenue to refund to the Insular Lumber Company the amount of P10,560.20 instead of P19,921.37, representing 25% of the specific tax paid on manufactured oil and motor fuel utilized by said company in the operation of its forest concession in the year 1963.

The undisputed facts of these cases are as follows:

Insular Lumber Company (Company for short), a corporation organized and existing under the laws of New York, U.S.A., and duly authorized to do business in...