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Comm. Of Internal Rev. vs. Cons. Res. Of Asia ,etal

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. CONSTRUCTION RESOURCES OF ASIA, INC., and THE COURT OF TAX APPEAL, respondents.

G.R. No. L-68230 | 1986-11-25

D E C I S I O N


GUTIERREZ, JR., J:

This is a petition for review of the decision of the respondent Court of Tax Appeals dated November 25, 1983, cancelling for lack of sufficient basis the assessment by the Commissioner of Internal Revenue of documentary and science stamps taxes against the private respondent in the amount of P89,400.00. Petitioner likewise appeals the resolution of the respondent court denying its motion for reconsideration.

The facts as found by the respondent court are not disputed:

"Petitioner is a domestic corporation, duly registered with the Overseas Construction Board as an overseas contractor (pars. I and II,...