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CIR vs. PNB

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, V. PHILIPPINE NATIONAL BANK, RESPONDENT.

G.R. No. 212699 | 2019-03-13

D E C I S I O N
 
J. REYES, JR., J.:
 
This petition for review on certiorari[1] under Rule 45 of the Rules of Court assails the Amended Decision[2] dated February 4, 2014 of the Court of Tax Appeals (CTA) En Banc in CTA EB Case No. 859, which ordered petitioner Commissioner of Internal Revenue (CIR) to refund respondent Philippine National Bank's (PNB's) excess and unutilized creditable withholding taxes (CWT) for the taxable year 2005, or to issue a tax credit certificate therefor in favor of PNB. The CTA's Resolution[3] dated May 27, 2014, which denied the CIR's motion for...