WebIn CIR v. Reyes, [18] the Court further explained:. In the present case, Reyes was not informed in writing of the law and the facts on which the assessment of estate taxes had been made:. She was merely notified of the findings by the CIR, who had simply relied upon the provisions of former Section 229 prior to its amendment by Republic Act (RA ... WebOn appeal by the Commissioner, the Court through its Second Division reversed the decision of the CTA and held that: chanrob1es virtual 1aw library (a) P&G-USA, and not private respondent P&G-Phil., was the proper party to claim the refund or tax credit here involved; chanrobles.com : virtual law library (b) "there is nothing in Section 902 or other …
G.R. No. 207039 - COMMISSIONER OF INTERNAL REVENUE
WebCIR VS SC JOHNSON & SON, INCS AND CA [G.R. No. 127105. June 25, 1999] JOHNSON AND SON, INC a domestic corporation organized and operating under the … WebThe rule in fraud cases is that the proof "must be clear and convincing" (Griffiths v. Comm., 50 F [2d] 782), that is, it must be stronger than the "mere preponderance of evidence" which would be sufficient to sustain a judgment on the issue of correctness of the deficiency itself apart from the fraud penalty. (Frank A. Neddas, 40 BTA 672). fischpatty
G.R. No. 150947 - Lawphil
WebThe CIR moved for reconsideration but the same was denied by the CTA Division in its Resolution12 dated September 1, 2016. On appeal to the CTA EB, the CIR claimed that the tax exemption in Section 40(C)(2) of the NIRC of 1997, as amended, does not cover the subject share swap transaction because respondents, prior to the exchange, already had ... WebJan 25, 2024 · Thus, the application of the higher excise tax rate for variant products is appropriate (₱19.91 per liter instead of ₱9.15 per liter) and SMC should not be entitled to a refund or issuance of a tax credit certificate. The CTA sided with SMC; hence, this petition by the CIR with the SC. WebThus, on April 20, 2004, Kepco filed before the Commissioner of Internal Revenue (CIR) a claim for tax refund covering unutilized input VAT payments attributable to its zero-rated sales transactions for taxable year 2002. 6 Two days later, on April 22, 2004, it filed a petition for review before the CTA. The case was docketed as C.T.A. Case No. 6965. 7 ... camp raymond az