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Commissioner of Internal Revenue Vs. St. Luke's Medical Center, Inc./St. Luke's Medical Center, Inc. Vs. Commissioner of Internal Revenue

COMMISSIONER OF INTERNAL REVENUE, Petitionn, versus ST. LUKE'S MEDICAL CENTER, INC., Respondent and ST. LUKE'S MEDICAL CENTER, INC., Petitioner versus COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 195909 and G.R. No. 195960 | 2012-09-26

SECOND DIVISION

D E C I S I O N 


CARPIO, J.: 


The Case 


These are consolidated 1 petitions for review on certiorari under Rule 45 of the Rules of Court assailing the Decision of 19 November 2010 of the Court of Tax Appeals (CTA) En Banc and its Resolution2 of 1 March 2011 in CTA Case No. 6746. This Court resolves this case on a pure question of law, which involves the interpretation of Section 27(B) vis-a-vis Section 30(E) and (G) of the National Internal Revenue Code of the Philippines (NIRC), on the income tax treatment of proprietary non-profit hospitals.

The Facts

St. Luke's Medical Center, Inc. (St. Luke's) is a hospital...