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Miguel J. Osorio Pension Foundation, Incorporated Vs. Court of Appeals and Commissioner of Internal Revenue

MIGUEL J. OSSORIO PENSION FOUNDATION, INCORPORATED, Petitioner, versus COURT OF APPEALS and COMMISSIONER OF INTERNAL REVENUE, Respondents.

G.R. No. 162175 | 2010-06-28

D E C I S I O N


CARPIO, J.:

The Case

The Miguel J. Ossorio Pension Foundation, Incorporated (petitioner or MJOPFI) filed this Petition for Certiorari[1] with Prayer for the Issuance of a Temporary Restraining Order and/or Writ of Preliminary Injunction to reverse the Court of Appeals' (CA) Decision[2] dated 30 May 2003 in CA-G.R. SP No. 61829 as well as the Resolution[3] dated 7 November 2003 denying the Motion for Reconsideration. In the assailed decision, the CA affirmed the Court of Tax Appeals' (CTA) Decision[4] dated 24 October 2000. The CTA denied petitioner's claim for refund of withheld creditable tax of P3,037,500 arising from...