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Pilipinas Shell Petroleum Corp. vs. Republic of the Philippines 547 SCRA 701

PILIPINAS SHELL PETROLEUM CORPORATION, Petitioner, versus REPUBLIC OF THE PHILIPPINES, represented by the BUREAU OF CUSTOMS, Respondent.

G.R. No. 161953 | 2008-03-06

D E C I S I O N 

CORONA, J.: 

This petition for review on certiorari[1] seeks to set aside the decision of the Court of Appeals (CA) in CA-G.R. SP No. 71756[2] and its resolution denying reconsideration.[3] 

The present controversy sprang from the cancellation of tax debit memos (TDMs) and the corresponding tax credit certificates (TCCs) assigned to petitioner Pilipinas Shell Petroleum Corporation (Shell) by various entities.[4] The assignment to Shell had the approval of the Board of Investments and the One Stop Shop Inter-Agency Tax Credit and Duty Drawback Center (Center). Some of these TCCs were subsequently accepted as...