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Team Sual Corp. vs. CIR

TEAM SUAL CORPORATION (FORMERLY MIRANT SUAL CORPORATION), PETITIONER, V. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. [G.R. No. 201132 (From CTA-EB No. 651), April 18, 2018] COMMISSIONER OF INTERNAL REVENUE, PETITIONER, V. TEAM SUAL CORPORATION (FORMERLY MIRANT SUAL CORPORATION), RESPONDENT. [G.R. No. 201133 (From CTA-EB No. 649), April 18, 2018] COMMISSIONER OF INTERNAL REVENUE, PETITIONER, V. TEAM SUAL CORPORATION (FORMERLY MIRANT SUAL CORPORATION), RESPONDENT.

G.R. Nos. 201225-26 (From CTA-EB Nos. 649 & 651) | 2018-04-18

D E C I S I O N
 
REYES, JR., J:
 
Nature of the Petitions
 
Challenged before the Court via Petitions for Review on Certiorari[1] under Rule 45 of the Rules of Court is the Consolidated Decision[2] of the Court of Tax Appeals (CTA) En Banc dated September 15, 2011 and its subsequent Resolution[3] dated March 21,2012 in CTA-EB Nos. 649 and 651. The assailed Decision and Resolution modified the Amended Decision[4] of the CTA Special First Division dated June 7, 2010 and partially granted Team Sual Corporation's (TSC) claim for refund in the amount of P123,110,001.68 representing unutilized...