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Commissioner of Internal Revenue Vs. Team [Philippines] Operations Corporation (formerly Mirant [Philippines] Operations Corporation)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. TeaM (PHILIPPINES) OPERATIONS CORPORATION [Formerly MIRANT (PHILIPPINES) OPERATIONS CORPORATION], Respondent.

G.R. No. 185728 | 2013-10-16

FIRST DIVISION

DECISION

VILLARAMA, JR., J.:

On appeal under Rule 45 is the August 27, 2008 Decision1 of the Court of Tax Appeals (CTA) En Bane in C.T.A. E.B. No. 369 which affirmed the August 29, 2007 Decision2 of the CTA First Division in CTA Case No. 6970 ordering petitioner Commissioner of Internal Revenue (CIR) to refund, or in the alternative, issue a tax credit certificate, in favor of respondent TeaM (Philippines) Operations Corporation3 the amount of P23,053,919.22 representing excess/unutilized creditable withholding taxes for the taxable year 2002. Petitioner likewise assails the November 28, 2008 Resolution4 of the CTA En Bane...