FIRST DIVISION
D E C I S I O N
DEL CASTILLO, J.:
Section 69 of the old National Internal Revenue Code (NIRC) allows unutilized tax credits to be refunded as long as the claim is filed within the prescriptive period. This, however, no longer holds true under Section 76 of the 1997 NIRC as the option to carry-over excess income tax payments to the succeeding taxable year is now irrevocable.
This Petition for Review on Certiorari[1] under Rule 45 of the Rules of Court seeks to set aside the January 25, 2007 Decision2 and the January 21, 2008 Resolution3 of the Court of Appeals (CA).
Factual Antecedents
Petitioner...
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