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Commissioner of Internal Revenue Vs. Court of Tax Appeals and Ayala Land, Inc.

COMMISSIONER OF INTERNAL REVENUE, Petitioner, versus COURT OF TAX APPEALS and AYALA LAND, INC., Respondents.

G.R. No. 190680 | 2012-09-13

FIRST DIVISION

R E S O L U T I O N


REYES, J.:

Subject of this petition for certiorari under Rule 65 of the Rules of Court is the Resolution 1 dated October 30, 2009 of the Court of Tax Appeals (CTA) en bane in CTA EB No. 402, which dismissed herein petitioner Commissioner of Internal Revenue's (CIR) petition for relief from judgment under Rule 38 of the Rules of Court.

The factual antecedents that led to the filing of this petition are as follows: In 2005, private respondent Ayala Land, Inc. (ALI) filed with theCTA a petition for review2 to question the CIR's assessment against it for
deficiency value-added tax (VAT) for the calendar year...