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Commissioner of Internal Revenue Vs. Kudos Metal Corporation

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus KUDOS METAL CORPORATION, Respondent.

G.R. No. 178087 | 2010-05-05

D E C I S I O N


DEL CASTILLO, J.:

The prescriptive period on when to assess taxes benefits both the government and the taxpayer.[1] Exceptions extending the period to assess must, therefore, be strictly construed.

This Petition for Review on Certiorari seeks to set aside the Decision[2] dated March 30, 2007 of the Court of Tax Appeals (CTA) affirming the cancellation of the assessment notices for having been issued beyond the prescriptive period and the Resolution[3] dated May 18, 2007 denying the motion for reconsideration.

Factual Antecedents

On April 15, 1999, respondent Kudos Metal Corporation filed its Annual Income Tax Return...