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Bank of the Philippine Islands vs. Commissioner of Internal Revenue

BANK OF THE PHILIPPINE ISLANDS, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.

G.R. No. 137002 | 2006-07-27

FIRST DIVISION
 
D E C I S I O N
 
CHICO-NAZARIO, J.:
 
This is a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Court, as amended, seeking to set aside a Decision [1] of the Court of Appeals dated 14 August 2004 ordering the petitioner to pay respondent Commissioner of Internal Revenue (CIR) deficiency documentary stamp tax of P690,030 for the year 1986, inclusive of surcharge and compromise penalty, plus 20% annual interest until fully paid. The Court of Appeals in its assailed Decision affirmed the Decision [2] of the Court of Tax Appeals (CTA) dated 31 May 1994.
 
From 28 February 1986 to 8 October...