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Sea-Land Service, Inc. vs Court of Appeals 357 SCRA 441

SEA-LAND SERVICE, INC., petitioner, vs. COURT OF APPEALS and COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. No. 122605 | 2001-04-30

D E C I S I O N

PARDO, J.:

The Case

Appeal via certiorari from the decision of the Court of Appeals affirming in toto that of the Court of Tax Appeals which denied petitioner's claim for tax credit or refund of income tax paid on its gross Philippine billings for taxable year 1984, in the amount of P870,093.12.[1]

The Facts

The facts, as found by the Court of Appeals, are as follows:

"Sea-Land Service Incorporated (SEA-LAND), an American international shipping company licensed by the Securities and Exchange Commission to do business in the Philippines entered into a contract with the United States Government to transport military household...