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CIR vs. CTA and Petron Corporation

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. COURT OF TAX APPEALS AND PETRON CORPORATION, RESPONDENT.

G.R. No. 207843 (Resolution) | 2018-02-14

R E S O L U T I O N
 
PERLAS-BERNABE, J.:
 
For the Court's resolution is a motion for reconsideration[1] filed by respondent Petron Corporation (Petron) on the Court's Decision[2] dated July 15, 2015 which set aside the Resolutions dated February 13, 2013[3] and May 8, 2013[4] issued by the Court of Tax Appeals (CTA) in CTA Case No. 8544 and thereby, dismissed the petition for review[5] before the court a quo for lack of jurisdiction and prematurity.
 
The Facts

On June 29, 2012, petitioner Commissioner of Internal Revenue (CIR) issued a Letter[6] interpreting Section 148(e) of the...