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Commissioner of Internal Revenue vs. Primetown Property Group Inc. 531 SCRA 436

COMMISSIONER OF INTERNAL REVENUE and ARTURO V. PARCERO in his official capacity as Revenue District Officer of Revenue District No. 049 (Makati), Petitioners, versus PRIMETOWN PROPERTY GROUP, INC., Respondent.

G.R. No. 162155 | 2007-08-28

D E C I S I O N 
 
CORONA, J.: 
 
This petition for review on certiorari[1] seeks to set aside the August 1, 2003 decision[2] of the Court of Appeals (CA) in CA-G.R. SP No. 64782 and its February 9, 2004 resolution denying reconsideration.[3] 
 
On March 11, 1999, Gilbert Yap, vice chair of respondent Primetown Property Group, Inc., applied for the refund or credit of income tax respondent paid in 1997. In Yap's letter to petitioner revenue district officer Arturo V. Parcero of Revenue District No. 049 (Makati) of the Bureau of Internal Revenue (BIR),[4] he explained that the increase in the cost of labor and...