Back

Commissioner of Internal Revenue vs. Court of Appeals, et al. 271 SCRA 605

COMMISSIONER OF INTERNAL REVENUE, petitioner vs. THE COURT OF APPEALS, THE COURT OF TAX APPEALS and ATENEO DE MANILA UNIVERSITY, respondents.

G.R. No. 115349 | 1997-04-18

D E C I S I O N


PANGANIBAN, J.:

In conducting researches and studies of social organizations and cultural values thru its Institute of Philippine Culture, is the Ateneo de Manila University performing the work of an independent contractor and thus taxable within the purview of then Section 205 of the National Internal Revenue Code levying a three percent contractor's tax? This question is answer by the Court in the negative as it resolves this petition assailing the Decision 1 of the Respondent Court of Appeals 2 in CA-G.R. SP No. 31790 promulgated on April 27, 1994 affirming that of the Court of Tax Appeals. 3

The Antecedent Facts

The...