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TFS Incorporated Vs. Commissioner of Internal Revenue

TFS, INCORPORATED, Petitioner, versus COMMISSIONER OF INTERNAL REVENUE, Respondent

G.R. No. 166829 | 2010-04-19

D E C I S I O N


DEL CASTILLO, J.:

Only in highly meritorious cases, as in the instant case, may the rules for perfecting an appeal be brushed aside.

This Petition for Review on Certiorari under Rule 45 of the Rules of Court seeks to set aside the November 18, 2004[1] Resolution of the Court of Tax Appeals (CTA) En Banc in C.T.A. EB No. 29 which dismissed petitioner's Petition for Review for having been filed out of time. Also assailed is the January 24, 2005[2] Resolution denying the motion for reconsideration.

Factual Antecedents

Petitioner TFS, Incorporated is a duly organized domestic corporation engaged in the pawnshop business....