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Atlas Consolidated Mining and Development Corporation vs. Commissioner of Internal Revenue

ATLAS CONSOLIDATED MINING AND DEVELOPMENT CORPORATION, Petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, Respondent.

G.R. No. 159471 | 2011-01-26

 
 
SECOND DIVISION
D E C I S I O N
 
PERALTA, J.:
 
For this Court's resolution is the Petition for Review on Certiorari under Rule 45 of the Revised Rules of Civil Procedure assailing the Decision1 dated April 19, 2001 and Resolution2 dated August 6, 2003 of the Court of Appeals (CA).
 
The facts, as shown in the records, are the following:
 
Under Section 100 of the Tax Code of the Philippines, petitioner is a zero-rated Value Added Tax (VAT) person for being an exporter of copper concentrates. According to petitioner, on January 20, 1994, it filed its VAT return for the fourth quarter of 1993,...