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Silicon Philippines, Inc. (Formerly Intel Philippines Manufacturing, Inc.) Vs. Commissioner of Internal Revenue

SILICON PHILIPPINES, INC., (formerly Intel Philippines Manufacturing, Inc.), Petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, Respondent. G.R. No.184360 & 184361 _________________________ COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. SILICON PHILIPPINES, INC., (formerly Intel PhilippinesManufacturing, Inc.), Respondent, G .R. No. 184384

G.R. Nos. 184360, 184361 & 194384 | 2014-02-14

FIRST DIVISION

DECISION

VILLARAMA, JR., J.:

Before us are three consolidated petitions for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, assailing (1) the Decision1 dated February 18, 2008 of the Court of Tax Appeals (CTA) En Banc in CTA E.B. No. 219; (2) the Decision2 dated February 20, 2008 of the CTA En Banc in CTA E.B. Case No. 209; and (3) the two Resolutions3 both dated September 2, 2008 of the CTA En Banc denying the motions for reconsideration from the aforementioned assailed decisions.

The facts as summarized by the CTA in Division and adopted by the CTA En Banc are as follows:

Silicon...