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Asian Transmission Corp vs. CIR [RESOLUTION]

ASIAN TRANSMISSION CORPORATION, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 230861 | 2022-02-14

R E S O L U T I O N
 
INTING, J.:
 
This resolves the Motion for Reconsideration[1] of the Court Decision[2] dated September 19, 2018 denying Asian Transmission Corporation's (ATC) Petition for Review on Certiorari[3] thereby affirming the Court of Tax Appeals (CTA) En Banc Decision[4] dated August 9, 2016 in CTA EB No. 1289.
 
The Antecedents
 
The crux of the present controversy lies in the validity of eight Waivers of the Defense of Prescription under the Statute of Limitations of the National Internal Revenue Code[5] (Waivers) executed successively by ATC, through...