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COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. PHILIPPINE NATIONAL BANK, RESPONDENT.

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. PHILIPPINE NATIONAL BANK, RESPONDENT.

G.R. No. 180290 |

SECOND DIVISION
 
D E C I S I O N

LEONEN, J.:

Before this court is a petition for review1 under Rule 45 of the Rules of Court, seeking to annul the October 1, 2007 decision2 and October 30, 2007 resolution3 of the Court of Tax Appeals En Banc in C.T.A. E.B. No. 285.
 
The assailed decision denied petitioner’s appeal and affirmed the January 30, 2007 decisionand May 30, 2007 resolution5 of the First Division of the Court of Tax Appeals, granting respondent a tax refund or credit in the amount of P23,762,347.83, representing unutilized excess creditable withholding taxes for taxable year 2000.  The...