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CIR vs. BPI

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, V. BANK OF THE PHILIPPINE ISLANDS, RESPONDENT.

G.R. No. 224327 | 2018-06-11

D E C I S I O N
 
PERALTA, J.:
 
For this Court’s resolution is the Petition for Review on Certiorari[1] under Rule 45 of the Revised Rules of Civil Procedure assailing the Decision[2] dated September 16, 2015 and Resolution[3] dated April 21, 2016 of the Court of Tax Appeals (CTAEn Banc in CTA EB No. 1173 (CTA CASE No. 8350) on petitioner Commissioner of Internal Revenue's (CIR) tax assessment against respondent Bank of the Philippine Islands (BPI).
 
The facts follow.
 
Citytrust Banking Corporation (CBC) filed its Annual Income Tax Returns for its Regular Banking Unit, and Foreign...