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COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. COURT OF TAX APPEALS AND CBK POWER COMPANY LIMITED, RESPONDENTS.

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. COURT OF TAX APPEALS AND CBK POWER COMPANY LIMITED, RESPONDENTS.

G.R. Nos. 203054-55 | 2015-07-29

THIRD DIVISION
 
D E C I S I O N

PERALTA, J.:

Before us is a petition for certiorari under Rule 65 which seeks to annul and set aside the Resolutions of the Court of Tax Appeals (CTA) dated December 23, 2011,[1] April 19, 2012,[2] and June 13, 2012[3] issued in CTA Case Nos. 8246 and 8302.
 
Private respondent CBK Power Company Limited is a special purpose entity engaged in all aspects of (1) design, financing, construction, testing, commissioning, operation, maintenance, management, and ownership of Kalayaan II pumped storage hydroelectric power plant, the new Caliraya Spillway in Laguna; and (2) the rehabilitation, expansion,...