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Commissioner of the Internal Revenue vs. Toledo

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. TOLEDO POWER COMPANY, RESPONDENT.

G.R. No. 183880 | 2014-01-20

D E C I S I O N
 
PERALTA, J.:
 
This resolves the Petition for Review on Certiorari under Rule 45 of the Rules of Court seeking the reversal of the Court of Tax Appeals (CTA) En Banc Decision[1] dated May 7, 2008, and Resolution[2] dated July 18, 2008.

The pertinent facts, as narrated by the CTA First Division, are as follows:

Petitioner (herein respondent Toledo Power, Inc.) is a general partnership duly organized and existing under Philippine laws, with principal office at Sangi, Toledo City, Cebu. It is principally engaged in the business of power generation and subsequent sale thereof to the National Power Corporation (NPC), Cebu...