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Mitsubishi vs. Commissioner

MITSUBISHI CORPORATION-MANILA BRANCH, PETITIONER, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 175772 * | 2017-06-05

DECISION
 
PERLAS-BERNABE, J.:
 
Assailed in this petition for review on certiorari[1] are the Decision[2] dated May 24, 2006 and the Resolution[3] dated December 4, 2006 of the Court of Tax Appeals (CTA) En Banc in C.T.A. EB No. 5, reversing the CTA Division's ruling[4] in CTA Case No. 6139 which granted the claim for refund of erroneously paid income tax and branch profit remittance tax (BPRT; collectively, subject taxes) filed by petitioner Mitsubishi Corporation - Manila Branch (petitioner) for the fiscal year that ended on March 31, 1998.
 
The Facts
 
On June 11, 1987, the...