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South African Airways vs. Commissioner of Internal Revenue

SOUTH AFRICAN AIRWAYS, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent

G.R. No. 180356 | 2010-02-16

D E C I S I O N

VELASCO, JR., J.:

The Case

This Petition for Review on Certiorari under Rule 45 seeks the reversal of the July 19, 2007 Decision[1] and October 30, 2007 Resolution[2] of the Court of Tax Appeals (CTA) En Banc in CTA E.B. Case No. 210, entitled South African Airways v. Commissioner of Internal Revenue. The assailed decision affirmed the Decision dated May 10, 2006[3] and Resolution dated August 11, 2006[4] rendered by the CTA First Division.

The Facts

Petitioner South African Airways is a foreign corporation organized and existing under and by virtue of the laws of the Republic of South Africa. Its principal office is located at...