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Prime Steel Mill vs. CIR

PRIME STEEL MILL, INCORPORATED, PETITIONER, VERSUS COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

G.R. No. 249153 | 2022-09-12

DECISION
 
DIMAAMPAO, J.:
 
This Petition for Review on Certiorari[1] impugns the Decision[2] dated 3 January 2019 and the Resolution[3] dated 27 August 2019 of the Court of Tax Appeals (CTA) En Banc in CTA EB Nos. 1678 and 1680, which affirmed petitioner's liability for deficiency income tax for taxable year 2005, and which denied petitioner's motion for partial reconsideration and respondent's motion for reconsideration, respectively.
 
The facts of this case are undisputed.
 
On 7 January 2009, petitioner Prime Steel Mill, Incorporated received a Preliminary Assessment Notice (PAN) dated 19 December 2008 from the...