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[2/2] Pilipinas Shell Petroleum Corporation Vs. Commissioner of Internal Revenue

[2/2] PILIPINAS SHELL PETROLEUM CORPORATION, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 172598 | 2007-12-21

LIABILITY CLAUSE

Both the TRANSFEROR and the TRANSFEREE shall be jointly and severally liable for any fraudulent act or violation of the pertinent laws, rules and regulations relating to the transfer of this TAX CREDIT CERTIFICATE. (Emphasis supplied.)

The above clause to our mind clearly provides only for the solidary liability relative to the transfer of the TCCs from the original grantee to a transferee. There is nothing in the above clause that provides for the liability of the transferee in the event that the validity of the TCC issued to the original grantee by the Center is impugned or where the TCC is declared to have been...