D E C I S I O N
CORONA, J.:
Petitioner Atlas Consolidated Mining and Development Corporation is engaged in the business of mining, production, and sale of various mineral products. On March 31, 1993, petitioner presented to respondent Commissioner of Internal Revenue applications for refund or tax credit of excess input taxes[1] for the second, third and fourth quarters of 1992 in the following amounts: P24,031,673 for the second quarter, P16,597,709.17 for the third quarter and P29,839,894.82 for the last. Petitioner attributed these claims to its sales of gold to the Central Bank, copper concentrates to Philippine Associated Smelting...
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