Back

CIR vs. Liquigaz Philippines Corporation

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. LIQUIGAZ PHILIPPINES CORPORATION, RESPONDENT. LIQUIGAZ PHILIPPINES CORPORATION, PETITIONER, VS. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 215534 and G.R. No. 215557 | 2016-04-18

D E C I S I O N
 
MENDOZA, J.:
 
Presented before us is a novel issue. When may a Final Decision on Disputed Assessment (FDDA) be declared void, and in the event that the FDDA is found void, what would be its effect on the tax assessment?

Assailed in these consolidated petitions for review on certiorari filed under Rule 45 of the Rules of Court are the May 22, 2014 Decision[1] and the November 26, 2014 Resolution[2] of the Court of Tax Appeals (CTA) En Banc which affirmed the November 22, 2012 Decision[3] of the CTA Division, Second Division (CTA Division).

Liquigaz Philippines Corporation (Liquigaz) is a corporation...