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Commissioner of Internal Revenue vs. Citytrust Banking Corporation.

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus CITYTRUST BANKING CORPORATION, Respondent.

G.R. No. 150812 | 2006-08-22

SECOND DIVISION

D E C I S I O N 

CORONA, J. 

The Commissioner of Internal Revenue (CIR) assails the decision[1] of the Court of Appeals (CA) and its resolution[2] upholding the decision of the Court of Tax Appeals (CTA) in CTA Case No. 4099 which ordered the refund of P13,314,506.14 to respondent Citytrust Banking Corporation (Citytrust)[3] as its alleged overpaid income taxes for the years 1984 and 1985. 

On May 28, 1991, the CTA ordered the CIR to grant Citytrust a refund in the amount of P13,314,506.14 representing Citytrust's overpaid income taxes for 1984 and 1985. The CIR filed a motion for reconsideration (MR) on the...