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BPI Leasing Corp vs. Court of Appeals and CTA

BPI LEASING CORPORATION, petitioner, vs. THE HONORABLE COURT OF APPEALS, COURT OF TAX APPEAL AND COMMISSIONER OF INTERNAL REVENUE, respondents.

G.R. No. 127624 | 2003-11-18

D E C I S I O N

AZCUNA, J.:

The present petition for review on certiorari assails the decision[1] of the Court of Appeals in CA-G.R. SP No. 38223 and its subsequent resolution[2] denying the motion for reconsideration. The assailed decision and resolution affirmed the decision of the Court of Tax Appeals (CTA) which denied petitioner BPI Leasing Corporation's (BLC) claim for tax refund in CTA Case No. 4252.

The facts are not disputed.

BLC is a corporation engaged in the business of leasing properties.[3] For the calendar year 1986, BLC paid the Commissioner of Internal Revenue (CIR) a total of P1,139,041.49 representing 4%...