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COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. EMBROIDERY AND GARMENTS INDUSTRIES (PHIL.), INC., respondent.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. EMBROIDERY AND GARMENTS INDUSTRIES (PHIL.), INC., respondent.

G.R. No. 96262 | 1999-03-22

D E C I S I O N

PARDO, J.:

The case is an appeal via certiorari from a decision of the Court of Appeals[1] affirming that of the Court of Tax Appeals[2] absolving respondent from liability for deficiency income tax and advance sales tax in the amounts of P2,756,241.68, and P3,500,798.47, respectively, for the years 1959 to 1961.

The facts may be related as follows:

On September 22, 1964, on the basis of a sworn report of an informer, the Courts of First Instance of Manila and Bulacan issued search warrants for the seizure of certain documents from the offices of respondent Embroidery and Garments Industries (Phil.), Inc. in Manila and...