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China Banking Corporation Vs. Commissioner of Internal Revenue

China Banking Corporation, Petitioner Vs. Commissioner of Internal Revenue, Respondent

G.R. No. 175108 | 2013-02-27

THIRD DIVISION 

DECISION

PERALTA, J.: 

This resolves the Petition for Review on Certiorari under Rule 45 of the Rules of Court which seeks the review and reversal of the Decision 1 dated June 16, 2006 and Resolution2 dated October 1 7, 2006 of the former Fifth Division of the Court of Appeals ( CA). 

The factual antecedents follow. 

For the four quarters of 1996, petitioner paid P93,119,433.50 as gross receipts tax ( GRT) on its income from the interests on loan investments, commissions, service and collection charges, foreign exchange profit and other operating earnings. 

In computing its...