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Commissioner of Internal Revenue vs. Kepco Ilijan Corp.

COMMISSIONER INTERNAL REVENUE, Petitioner, vs. KEPCO ILIJAN CORPORATION, Respondent. Present: SERENO, C.J, CARPIO, VELASCO, JR., LEONARDO-DE CASTRO, BRION, PERALTA, BERSAMIN, DEL CASTILLO,* PEREZ, MENDOZA, REYES, PERLAS-BERNABE, LEONEN, JARDELEZA,* and CAGUIOA,JJ.

G.R. No. 199422 | 2016-06-26

DECISION
 
PERALTA,J. :
 
This is a petition for Review on Certiorari under Rule 45 of the Rules of Court seeking the reversal of the Resolutions1 dated July 27, 20112 and November 15, 20113 of the Court of Tax Appeals (CTA) En Banc.
 
The facts follow.
 
For the first4 and second5 quarters of the calendar year 2000, respondent filed its Quarterly value-added tax (VA1) returns with the Bureau of Internal Revenue (BIR). It also filed the Application for Zero Rated Sales for calendar year 2000 which was duly approved by the BIR.6
 
Thereafter, respondent filed with the BIR its claim for refund in the amount of P49,569,448.73...