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Philippine Geothermal, Inc. vs. The Commissioner of Internal Revenue.

PHILIPPINE GEOTHERMAL, INC., Petitioner, versus THE COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 154028 | 2005-07-29

FIRST DIVISION

D E C I S I O N 

QUISUMBING, J.: 

The present petition for review on certiorari assails the September 14, 2001 Decision[1] and June 14, 2002 Resolution[2] of the Court of Appeals in CA-G.R. SP No. 54730, which affirmed the April 21, 1999 Decision[3] of the Court of Tax Appeals in C.T.A. Case No. 5541. 

The facts of the case as found by the Court of Appeals and Court of Tax Appeals are as follows: 

Petitioner is a resident foreign corporation licensed by the Securities and Exchange Commission (SEC) to engage in the exploration, development and exploitation of geothermal energy and resources in the...