Commissioner of Internal Revenue (CIR) vs. United Salvage and Towage (Phils.), Inc Summary

COMMISSIONER INTERNAL REVENUE, Petitioner, vs. UNITED SALVAGE AND TOW AGE (PHILS.), INC., Respondent.

G.R. No. 197515 | 2014-07-02

Statutory construction, an administrative rule interpretive of a statute, and not declarative of certain rights and corresponding obligations, is given retroactive effect as of the date of the effectivity of the statute
Tax assessment; It is not the mere request for reinvestigation, but the granting of the same, that tolls or suspends the running of the statute of limitations
Validity of a tax assessment is determined by the governing law at the time such assessment was issued

THIRD DIVISION

DECISION

PERAL TA, J.:

Before the Court is a petition for review on certiorari under Rule 45 of the Revised Rules of Court which seeks to review, reverse and set aside the Decision¹ of the Court of Tax Appeals En Banc (CTA En Banc), dated June 27, 2011, in the case entitled Commissioner of Internal Revenue v. United Salvage and Towage (Phils.), Inc. (USTP), docketed as C.T.A. EB No. 662.

The facts as culled from the records:

Respondent is engaged in the business of sub-contracting work for service contractors engaged in petroleum operations in the Philippines.² During the taxable...