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CIR vs. SOJ and MCWD

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, V. THE SECRETARY OF JUSTICE AND METROPOLITAN CEBU WATER DISTRICT (MCWD), RESPONDENTS.

G.R. No. 209289 | 2018-07-09

D E C I S I O N
 
TIJAM, J.:
 
Before Us is a Petition for Review on Certiorari[1] filed by petitioner Commissioner of Internal Revenue (CIR), assailing the Decision[2] dated January 23, 2013 and Resolution[3] dated August 29, 2013 of the Court of Appeals (CA) in CA-G.R. SP No. 117577 dismissing the petition for certiorari filed by CIR.
 
The Antecedent Facts
 
Metropolitan Cebu Water District (respondent) received a Preliminary Assessment Notice from the Bureau of Internal Revenue (BIR) for alleged . tax deficiencies for the year 2000 in the total amount of P70,660,389.00, representing alleged...