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Commissioner of Internal Revenue vs. Philippine National Bank

COMMISSIONER OF INTERNAL REVENUE, Petitioner, vs. PHILIPPINE NATIONAL BANK, Respondent. Present: SERENO, C.J., LEONARDO-DE CASTRO, BERSAMIN, PERLAS-BERNABE, and CAGUIOA,JJ

G.R. No. 195147 | 2016-07-11

DECISION
 
BERSAMIN, J.:
 
At issue is whether or not the respondent bank's interbank call loans transacted in 1997 were subject to documentary stamp taxes.
 
The petitioner appeals the September 21, 2010 decision rendered in C.T.A. EB Case No. 512,1 whereby the Court of Tax Appeals (CTA) En Banc affirmed the cancellation of Assessment No. 97-000064 for deficiency documentary stamp taxes imposed on the interbank call loans of respondent Philippine National Bank (PNB); and the resolution issued on January 10, 20112 denying the petitioner's motion for reconsideration.
 
Antecedents
 
On March 23, 2000, the petitioner...