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CIR vs CA and Carnation Phils., Inc.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. COURT OF APPEALS, COURT OF TAX APPEALS and CARNATION PHILIPPINES, INC. (now merged with Nestle Phils. Inc.), respondent.

G.R. No. 115712 | 1999-02-25

D E C I S I O N
 
PURISIMA, J.:
 
Before the Court is an appeal from the decision of the Court of Appeals[1] dated May 31, 1994, which affirmed in toto the decision of the Court of Tax Appeals[2] dated January 26, 1993, the dispositive portion of which reads:
 
"WHEREFORE, the Court, finds the assessments for allegedly deficient income and sales taxes for petitioner's fiscal year ending September 30, 1981 covered by Demand Letter NO. FAS-1B-81-87 and Assessment Notices Nos. FAS-1-81-87-005824, FAS-4-81-87-005825 and FAS-4-81-87-005826 (all dated July 29, 1987) in the total amount of P19,535,183.44 to...