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Commissioner of Internal Revenue vs. Ayala Securities Corp.

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. AYALA SECURITIES CORPORATION and THE HONORABLE COURT OF TAX APPEALS, respondents.

G.R. No. L-29485 | 1980-11-21

D E C I S I O N


TEEHANKEE, J.:

Before the court is petitioner Commissioner of Internal Revenue's motion for reconsideration of the Court's decision of April 8, 1976 wherein the Court affirmed in toto the appealed decision of respondent Court of Tax Appeals, the dispositive portion of which provides as follows:

"WHEREFORE, the decision of the respondent Commissioner of Internal Revenue assessing petitioner the amount of P758,687.04 as 25% surtax and interest is reversed. Accordingly, said assessment of respondent for 1955 is hereby cancelled and declared of no force and effect. Without pronouncement as to costs."

This Court's decision...