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China Banking Corporation Vs. The Commsissioner of Internal Revenue

CHINA BANKING CORPORATION, Petitioner, versus THE COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 172359 | 2009-10-02

D E C I S I O N


PERALTA, J.:

Before this Court is a Petition for Review on Certiorari[1] under Rule 45 of the Rules of Court seeking to set aside the January 3, 2006 Decision[2] and March 20, 2006 Resolution[3] of the Court of Tax Appeals (CTA) En Banc in C.T.A. EB No. 66 (C.T.A Case No. 6400).

The facts of the case.

Petitioner China Banking Corporation, a universal banking corporation duly organized and existing under and by virtue of the laws of the Republic of the Philippines, was engaged in the transaction of accepting special savings deposits (SSD), otherwise known as "Savings Plus Deposit.[4]

On September 23, 1999, petitioner...