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Cyanamid Philippines vs Court of Appeals 322 SCRA 638

CYANAMID PHILIPPINES, INC., petitioner, vs. THE COURT OF APPEALS, THE COURT OF TAX APPEALS and COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. No. 108067 | 2000-01-20

D E C I S I O N 

QUISUMBING, J.: 

Petitioner disputes the decision1 [Rollo, pp. 25-34.] of the Court of Appeals which affirmed the decision2 [CA Rollo, pp. 19-28.] of the Court of Tax Appeals, ordering petitioner to pay respondent Commissioner of Internal Revenue the amount of three million, seven hundred seventy-four thousand, eight hundred sixty seven pesos and fifty centavos (P3,774,867.50) as 25% surtax on improper accumulation of profits for 1981, plus 10% surcharge and 20% annual interest from January 30, 1985 to January 30, 1987, under Sec. 25 of the National Internal Revenue Code. 

The Court of Tax Appeals made the...