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CIR vs. Toledo Power Company

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. TOLEDO POWER COMPANY, RESPONDENT. [G.R. No. 196451] TOLEDO POWER COMPANY, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 196415 | 2015-12-02


D E C I S I O N
 
DEL CASTILLO, J.:
 
The burden of proving entitlement to a tax refund rests on the taxpayer.

Before this Court are Consolidated Petitions for Review on Certiorari[1] assailing the November 22, 2010 Decision[2] and the April 6, 2011 Resolution[3] of the Court of Tax Appeals (CTA) in CTA EB Nos. 623 and 629.

Factual Antecedents

Toledo Power Corporation (TPC) is a general partnership principally engaged in the business of power generation and sale of electricity to the National Power Corporation (NPC), Cebu Electric Cooperative III (CEBECO), Atlas Consolidated Mining and Development Corporation...