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TRIDHARMA Marketing Corp., vs. Court of Tax etc.

TRIDHARMA MARKETING CORPORATION, Petitioner, vs. COURT OF TAX APPEALS, SECOND DIVISION, AND THE COMMISSIONER OF INTERNAL REVENUE, Respondents. Present: SERENO, C.J., LEONARDO-DE CASTRO, BERSAMIN, PERLAS-BERNABE, and CAGUIOA,JJ

G.R. No. 215950 | 2016-06-20

DECISION
 
BERSAMIN, J.:
 
In this special civil action for certiorari,1 the taxpayer assails the resolutions issued on July 8, 20142 and December 22, 20143 in CTA Case No. 8833 whereby the Court of Tax Appeals (CTA), Second Division, granted its motion for suspension of the collection of tax but required it to post a surety bond amounting to P4,467,391,881.76.
 
The relevant facts follow.
 
On August 16, 2013, the petitioner received a Preliminary Assessment Notice (PAN) from the Bureau of Internal Revenue (BIR) assessing it with various deficiency taxes - income tax (IT), value-added tax (VAT), withholding tax on compensation...