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Bank of the Philippine Islands Vs. Commissioner of Internal Revenue

BANK OF THE PHILIPPINE ISLANDS, Petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 181836 | 2014-07-09

SECOND DIVISION
 
DECISION

CARPIO, J.:?
 
The Case

This petition for review1 assails the Decision2 promulgated on 29 May 2007 as well as the Resolution3 promulgated on 12 February 2008 by the Court of Appeals (CA) in CA-G.R. SP No. 63640. The CA reversed the Decision4 of the Court of Tax Appeals (CTA), dated 12 February 2001, and reinstated Assessment No. FAS-5-85-89-000988 requiring petitioner Bank of the Philippine Islands (BPI) to pay the amount of Pl,259,884.50 as deficiency documentary stamp tax (DST) for the taxable year 1985, inclusive of the compromise penalty.
 
The Facts

BPI,...