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CE Casecnan & Energy Company vs. Commisioner of Internal Revenue

CE CASECNAN WATER AND ENERGY COMPANY, INC., PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 203928 | 2015-07-22

DECISION
 
LEONEN, J.:
 
The thirty (30)-day period provided in Section 112 of the 1997 National Internal Revenue Code to appeal the decision of the Commissioner of Internal Revenue or its inaction is statutorily provided. Failure to comply is a jurisdictional error. The window of exemption created in Commissioner of Internal Revenue v. San Roque Power Corporation[1] is limited to premature filing of the judicial remedy. It does not cure lack of jurisdiction due to late filing.

This Petition for Review on Certiorari[2] seeks to annul and set aside the Decision[3] dated June 26, 2012 and Resolution[4] dated October 4, 2012 of the Court...