D E C I S I O N
AUSTRIA-MARTINEZ, J.:
Herein Petition for Review on Certiorari under Rule 45 of the Rules of Court assails the May 28, 2002 Decision[1] and October 16, 2002 Resolution[2] of the Court of Appeals (CA) in CA-G.R. SP No. 55470[3] which affirmed the October 5, 1999 Decision[4] of the Court of Tax Appeals (CTA) in CTA Case No. 5611.
The facts are as stated by the CTA.[5]
In its Bureau of Internal Revenue (BIR) Form No. 1702 or Corporation/Partnership Annual Income Tax Return[6] for fiscal year 1995, Banco Filipino Savings and Mortgage Bank (petitioner) declared a net operating loss of P211,476,241.00 and total tax credit of...
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