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Kepco Philippines Corporation Vs. Commissioner of Internal Revenue

KEPCO PHILIPPINES CORPORATION, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent

G.R. No. 179356 | 2009-12-14

D E C I S I O N


CARPIO MORALES, J.:

Korea Electric Power Corporation (KEPCO) Philippines Corporation (petitioner) is an independent power producer engaged in selling electricity to the National Power Corporation (NPC).

After its incorporation and registration with the Securities and Exchange Commission on June 15, 1995, petitioner forged a Rehabilitation Operation Maintenance and Management Agreement with NPC for the rehabilitation and operation of Malaya Power Plant Complex in Pililia, Rizal.[1]

On September 30, 1998, petitioner filed with the Commissioner of Internal Revenue (respondent) administrative claims for tax refund in the...