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COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. PILIPINAS SHELL PETROLEUM CORPORATION, RESPONDENT.

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. PILIPINAS SHELL PETROLEUM CORPORATION, RESPONDENT.

G.R. No. 192398 | 2014-09-29

THIRD DIVISION
 
D E C I S I O N

VILLARAMA, JR., J.:

Before us is a petition for review on certiorari filed by petitioner Commissioner of Internal Revenue, who seeks to nullify and set aside the September 10, 2009 Decision1 of the Court of Appeals (CA) in CA-G.R. SP No. 77117.  The CA had affirmed the Decisionof the Court of Tax Appeals ordering petitioner to refund, or in the alternative, issue a tax credit certificate in favour of Pilipinas Shell Petroleum Corporation (respondent) in the amount of P22,101,407.64 representing the latter’s erroneously paid documentary stamp tax for the taxable year 2000....