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Fort Bonifacio Development Corp. vs CIR

FORT BONIFACIO DEVELOPMENT CORPORATION, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE AND REVENUE DISTRICT OFFICER, REVENUE DISTRICT NO. 44, TAGUIG AND PATEROS, BUREAU OF INTERNAL REVENUE, RESPONDENTS. [G.R. No. 18003] FORT BONIFACIO DEVELOPMENT CORPORATION, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE AND REVENUE DISTRICT OFFICER, REVENUE DISTRICT NO. 44, TAGUIG AND PATEROS, BUREAU OF INTERNAL REVENUE, RESPONDENTS. [G.R. No. 181092] 5 FORT BONIFACIO DEVELOPMENT CORPORATION, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE AND REVENUE DISTRICT OFFICER, REVENUE DISTRICT NO. 44, TAGUIG AND PATEROS, BUREAU OF INTERNAL REVENUE, RESPONDENTS.

G.R. No. 175707 and G.R. No. 18003 and G.R. No. 181092 | 2014-11-19

FIRST DIVISION
D E C I S I O N

LEONARDO-DE CASTRO, J.:

The Court has consolidated these three petitions as they involve the same parties, similar facts and common questions of law. This is not the first time that Fort Bonifacio Development Corporation (FBDC) has come to this Court about these issues against the very same respondents, and the Court En Banc has resolved them in two separate, recent cases1 that are applicable here for reasons to be discussed below.
 
G.R. No. 175707 is an appeal by certiorari pursuant to Rule 45 of the 1997 Rules of Civil Procedure from (a) the Decision2 dated April 22, 2003 of the Court of Appeals...