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Bank of the Philippine Islands (BPI) vs. Commissioner of Internal Revenue (CIR)

BANK OF THE PHILIPPINE ISLANDS, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent

G.R. No. 139736 | 2005-10-17

D E C I S I O N
 
CHICO-NAZARIO, J.:
 
This Petition for Review on Certiorari, under Rule 45 of the 1997 Rules of Civil Procedure, assails the Decision of the Court of Appeals in CA-G.R. SP No. 51271, dated 11 August 1999,[1] which reversed and set aside the Decision of the Court of Tax Appeals (CTA), dated 02 February 1999,[2] and which reinstated Assessment No. FAS-5-85-89-002054 requiring petitioner Bank of the Philippine Islands (BPI) to pay the amount of P28,020.00 as deficiency documentary stamp tax (DST) for the taxable year 1985, inclusive of the compromise penalty.
 
There is hardly any controversy as to the factual...