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Oceanagold (Philippines) vs. CIR

OCEANAGOLD (PHILIPPINES), INC. PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

G.R. No. 234614 | 2023-06-14

D E C I S I O N
 
DIMAAMPAO, J.:
 
This Petition for Review on Certiorari[1] oppugns the Decision[2] and Resolution[3] of the Court of Tax Appeals (CTA) sitting en banc in CTA EB No. 1222, which affirmed the denial of the petition filed by Oceanagold (Philippines), Inc. (petitioner) before the CTA Second Division for lack of jurisdiction, and which denied its Motion for Reconsideration[4] and Supplement to Motion for Reconsideration[5] thereof, respectively.

The material operative facts are as follows:

 
On June 20, 1994, Climax-Arimco Mining Corporation (then known as Arimco Mining...