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Procter & Gamble Phil. Mfg.Corp. vs. CIR

PROCTER AND GAMBLE PHILIPPINE MANUFACTURING CORPORATION, petitioner, vs. THE COMMISSIONER OF INTERNAL REVENUE and the COURT OF TAX APPEALS, respondents.

G.R. No. 33425 | 1989-01-20

D E C I S I O N


GRIá'O-AQUINO, J.:

This is a petition for review of the decision of the Court of Tax Appeals dated October 30, 1970, affirming the resolution of the Commissioner of Internal Revenue finding the petitioner liable for deficiency sales tax plus surcharge for the years 1951 up to the first quarter of 1956 in the sum of P124,664.60, on its sales of lard, soap and margarine. The issue in this case involves the proper computation of the 7% sales tax under Section 186 of the Internal Revenue Code.

The facts are stated in the decision of the Tax Court as follows:

"Petitioner is a manufacturer of lard, soap and margarine the...