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CIR vs. HSBC

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. THE HONGKONG SHANGHAI BANKING CORPORATION LIMITED PHILIPPINE BRANCH, respondent.

C.T.A. EB CASE NO. 1257 | 2016-05-17

EN BANC
 
[C.T.A. EB CASE NO. 1257. May 17, 2016.]
(C.T.A. Case No. 8428)
 
COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. THE HONGKONG SHANGHAI BANKING CORPORATION LIMITEDPHILIPPINE BRANCH, respondent.
 
DECISION
 
MINDARO-GRULLA, J:

Submitted for decision is a Petition for Review for the Court En Banc under Rule 4, Section 2 (a) (1), in relation to Rule 8, Section 4 (b) of the 2005 Revised Rules of the Court of Tax Appeals (RRCTA),1 as amended, of the Decision2 dated October 13, 2014, rendered by the Third Division of this Court in CTA Case No. 8428, and its Resolution3 dated December 10, 2014.
 
Petitioner assailed both...