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COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. THE STANLEY WORKS SALES (PHILS.), INCORPORATED, RESPONDENT.

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. THE STANLEY WORKS SALES (PHILS.), INCORPORATED, RESPONDENT.

G.R. No. 187589 | 2014-12-03

FIRST DIVISION
 
D E C I S I O N

SERENO, C.J.:

This is a Petition for Review on Certiorari1 filed by the Commissioner of Internal Revenue (petitioner) under Rule 45 of the 1997 Rules of Civil Procedure assailing the Court of Tax Appeals En Banc (CTA En Banc) Decision2 dated 27 February 2009 and Resolution3 dated 24 April 2009 in C.T.A. EB No. 406.

THE FACTS
 
The pertinent findings of fact of the CTA En Banc are as follows:

Petitioner is the duly appointed officer of the Bureau of Internal Revenue (BIR) mandated to exercise the powers and perform the duties of his office including, among others, the power to decide...