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National Development Company (NDC) vs. Commissioner of Internal Revenue (CIR) 151 SCRA 472

NATIONAL DEVELOPMENT COMPANY, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.

G.R. No. L-53961 | 1987-06-30

D E C I S I O N


CRUZ, J.:

We are asked to reverse the decision of the Court of Tax Appeals on the ground that it is erroneous, We have carefully studied it and find it is not; on the contrary, it is supported by law and doctrine. So finding, we affirm.

Reduced to simplest terms, the background facts are as follows.

The National Development Company entered into contracts in Tokyo with several Japanese shipbuilding companies for the construction of twelve ocean-going vessels. 1 The purchase price was to come from the proceeds of bonds issued by the Central Bank. 2 Initial payments were made in cash and through irrevocable letters of credit. 3...