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Procted and Gamble Asia Pte Ltd. Vs. Commissioner of Internal Revenue

PROCTER & GAMBLE ASIA PTE LTD., Petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 202071 | 2014-02-19

FIRST DIVISION

RESOLUTION

SERENO, CJ:

This is a Petition for Review on Certiorari under Rule 45 of the Rules of Court assailing the Court of Tax Appeals (CTA) En Banc Decision1 and
Resolution2 in CTA EB No. 746, which denied petitioner's claim for refund of unutilized input value-added tax (VAT) for not observing the mandatory 120-day waiting period under Section 1123 of the National Internal Revenue Code.

On 26 September and 13 December 2006, petitioner filed administrative claims with the Bureau of Internal Revenue (BIR) for the refund or credit of the input VAT attributable to the former’s zero-rated sales covering the periods 1 July-30...