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CBK POWER COMPANY LIMITED, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. [G.R. NOS. 193407-08] COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. CBK POWER COMPANY LIMITED, RESPONDENT.

CBK POWER COMPANY LIMITED, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. [G.R. NOS. 193407-08] COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. CBK POWER COMPANY LIMITED, RESPONDENT.

G.R. Nos. 193383-84 | 2015-01-14

FIRST DIVISION
 
D E C I S I O N

PERLAS-BERNABE, J.:

Assailed in these consolidated petitions for review on certiorari1 are the Decision2 dated March 29, 2010 and the Resolutiondated August 16, 2010 of the Court of Tax Appeals (CTA) En Banc in C.T.A. E.B. Nos. 469 and 494, which affirmed the Decision4 dated August 28, 2008, the Amended Decision5 dated February 12, 2009, and the Resolution6 dated May 7, 2009 of the CTA First Division in CTA Case Nos. 6699, 6884, and 7166 granting CBK Power Company Limited (CBK Power) a refund of its excess final withholding tax for the taxable years 2001 to 2003.

The Facts
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