DISSENTING OPINION
CARPIO, J.:
I dissent. I reiterate my view that petitioner is not entitled to a refund or credit of any input VAT, as explained in my dissenting opinions in Fort Bonifacio Development Corporation v. Commissioner of Internal Revenue,1 involving an input VAT refund of P 347,741,695.74 and raising the same legal issue as that raised in the present case.
The majority grants petitioner an 8o/o transitional input VAT refund or credit of P 359,652,009.47 in relation to petitioner's output VAT for the first quarter of 1997. Petitioner argues that there is nothing in Section 105 of the old National...
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