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CIR vs CA, Central Vegetable Manufacturing, et al

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. THE COURT OF APPEALS CENTRAL VEGETABLE MANUFACTURING CO., INC., and GONZAGA-REYES, THE COURT OF TAX APPEALS, respondents.

G.R. No. 107135 | 1999-02-23

D E C I S I O N


PURISIMA, J.:

Before the Court is a Petition for Review on Certiorari from the judgment of the Court of Appeals affirming in toto the decision of the Court of Tax Appeals which required the Commissioner of Internal Revenue to credit the sales taxes paid by Central Vegetable Oil Manufacturing Co., Inc. (CENVOCO) on containers and packaging materials of its milled products, against the deficiency miller's tax due thereon for the year 1986.

As culled in the decision of the Court of Tax Appeals, the undisputed facts are, as follows:

"Petitioner (private respondent CENVOCO herein) is a manufacturer of edible and...