CTA EB No. 1831 (CTA Case No. 8924) Page 5 of 22 Thereafter, First Sumiden filed a Reply in CTi Case No. 8924 on February 20, 2015 alleging that the Commissioner's right to assess First Sumiden for deficiency taxes for taxable year 2009 has already prescribed. Allegedly, Hisahiro Miyake, First Sumiden's President and Chairman …
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Assailed in this Petition for Review on Certiorari are the December 22, 2016 Decision 1 and June 13, 2017 Resolution 2 of the Court of Tax Appeals (CTA) En Banc in CTA EB No. 1342 which affirmed the May 8, 2015 Decision 3 and the July 20, 2015 Resolution 4 of the CTA Second Division in C.T.A. AC No. 122.. The Antecedents Respondent protested the …
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(CTA EB Case 1465) The City Treasurer of Makati made an assessment for deficiency local taxes against the taxpayer. Meanwhile, the taxpayer tried to apply for the renewal of its business permit, but the City of Makati refused to issue the same due to an alleged business tax deficiency of the taxpayer for a prior year. ...
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revenue, cta eb nos. 1886 and 1887 (cta case no. 9021) dated january 21, 2020. a warrant of distraint and/or levy, issued by the commissioner of internal revenue (cir) after issuance of the final assessment notice and formal letter of demand, constitutes an act of the cir which may be the subject of an appeal to the cta. alphaland southgate
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cta eb no. case. date. 2481: commissioner of internal revenue v. bw shipping philippines, inc. december 22, 2022: 2458: lead export and agro-development corporation v. commissioner of internal revenue. december 13, 2022: 2526: larry e. segaya/les engineering and construction v. commissioner of the bureau of internal revenue. december 13, 2022: …
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cta eb no. 2.1.5.j! (cta case no. 9255) cir v. ncr cebu development center, inc. page 3 of8 x- -----x i. the honorable court en banc erred in ruling that respondent is not liable for …
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(Petron Corporation, vs Commissioner of Internal Revenue, CTA EB No. 1835 (CTA Case No. 9111), July 19, 2019) PAN and FAN/FLD must be served and received by the Taxpayer stating the laws and the facts in which the assessment is based within the three-year prescriptive period to assess by the BIR in order for the assessment to be …
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The Court of Tax Appeals (CTA) was created on June 16, 1954, through the enactment of Republic Act No. 1125 (R.A. 1125). Considering its limited jurisdiction then, it had only …
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CTA EB CASE NO. 1535 (CTA Case No. 8655) Page 2of18 Decision"), and the Resolution4 dated October 3, 2016 ("Assailed Resolution"), rendered by the Court of Tax Appeals (" CTA") First Division ("Court in Division") in CTA Case No. 8655, praying for the Court En Bane to (1) give due course to the present Petition for
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Market Strategic Firm, Inc., CTA EB No. 2281 (9 February 2022) Strict adherence to the schedule of penalties listed under Revenue Memorandum Order (RMO) …
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(CTA EB No. 1786, promulgated 13 June 2019) Expansion project Amending the definition of 'top withholding agents' The definition of 'top withholding agents' (TWAs) has been amended to refer to those taxpayers whose gross sales/receipts or gross purchases, or claimed deductible itemized expenses, as the case may be, amounted to
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However, in a recent Court of Tax Appeals ( CTA) en banc case ( CTA EB 2013 dated June 30, 2020), the court effectively refuted the BIR's resolute stand and held that for purposes of computing the IAET, the additional paid- in capital ( APIC) or premium paid over the par value of shares should be included in the corporation's paid- up ...
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CTA EB No. 2489 (CTA Case No. 9758) Commissioner of Internal Revenue vs. CHUN LANG CHAN, then operating under business name TOKAI RUBBER PRODUCTS, represented by Li Chuan Chang Page 2 of23 x-----x taxable period January 1, 2014 to November 13, 2014, in the petitioner's motion for reconsideration, respectively.) ...
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CTA EB No. 2279 (CTA Case No. 8485) Present: DEL ROSARIO, P.J., CASTANEDA, JR., UY, RINGPIS-LIBAN, MANAHAN, BACORRO-VILLENA, MODESTO-SAN PEDRO) …
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CTA EB NO. 1324 Page 2 of 14 WHEREFORE, premises considered, the instant Petition for Review is hereby GRANTED. Accordingly, the Final Assessment Notice dated July 25, 2011 and the attached Assessment Notice Nos. F-041-LNTF-07-VT-060 and F-041-LNTF-07-IT-060 assessing and demanding from
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The CIR appealed the case to the Court (G.R. No. 224327). 15. In the 2018 Case, the CIR argued as follows: first, the letter dated February 5, 1992 was a "final decision" on the assessment. Under the law, Citytrust had 30 days from the time of the letter's issuance to appeal it to the CTA.
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The CTA denied the Motion for Reconsideration filed by the BIR stating that the deficiency is fatal to BIR's cause since a motion without a notice of hearing is considered a mere scrap of paper. Jurisprudence had been categorical in treating a litigious motion without a valid notice of hearing as a mere scrap of paper.
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This is a PDF document of the decision of the Court of Tax Appeals En Banc in the case of Commissioner of Internal Revenue vs. Ma. Jethra B. Pascual, dated May 5, 2022. The …
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March 22, 2017. G.R. No. 213943. COMMISSIONER OF INTERNAL REVENUE, Petitioner vs PHILIPPINE DAILY INQUIRER, INC., Respondent D E C I S I O N. CARPIO, J.: The Case. Before the Court is a petition for review1 assailing the 4 November 2013 Decision2 and the 1 August 2014 Resolution3 of the Court of Tax. Appeals (CTA) En Banc in CTA …
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CTA EB No. 2415 (CTA Case No. 9433) Commissioner of Internal Revenue vs. Tann Philippines, Incorporated Page 3 of 36 x-----x for the one-day late payment of its Quarterly VAT for the 41h quarter of2013, broken down as follows:7 On October 8, 2014, respondent, through its counsel, filed ...
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Dunlevy Food Corporation, CTA EB No. 2294 (8 February 2022) Read a June 2022 report prepared by the KPMG member firm in the Philippines . Print friendly version. Share. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited …
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In its Resolution dated December 10, 2014, the CTA Division denied CIR's motion for reconsideration. CT A EB Ruling In the assailed Decision, the CTA EB affirmed the findings of the CTA Division. The CTA EB reiterated that "Goodwill" is an intangible asset, cannot exist independently of the business, nor can it be sold, purchased or transferred
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CTA EB No. 1786 Page 3 of 17 sole ground that petitioner did not strictly comply with the invoicing requirements for zero-rated sales. For CY 2010, respondent [now petitioner] issued Letter of Authority No. LOA-43A-2011-00000642 on October 11, 2010 authorizing Revenue Officer ('RO') Carmencita Villanueva and
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LBT.18 In this regard, the CTA EB found it unnecessary to remand the case to the RTC.19 Petitioner filed a Motion for Reconsideration but the same was denied by the CTA EB in its Resolution dated April 13, 2016.20 Hence, this Petition.21 The Issues Based on the submissions of the parties, the following issues are for the Court's resolution:
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February 3, 2021 of the Court of Tax Appeals (CTA) En Banc in CTA EB No. 2047 for failure of petitioner Commissioner oflnternal Revenue (petitioner) to show any reversible error …
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Resolution, dated 24 May 2022, of the Court of Tax Appeals en bane, in CTA EB No. 2241 (CTA Case No. 10198). The assailed Decision and Resolution dismissed the Petition for Review filed by the petitioner Department of Energy, against the Warrants ofDistraint and/ or Levy and Garnishment issued by the Commissioner of Internal Revenue, for lack ...
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Solutions Using Renewable Energy Inc., CTA EB 2387, June 23, 2022). Consequently, the issuance of the FAN and FLD before the expiration of the 15-day period violates the taxpayer's right to due process even if the taxpayer was able to submit a "well-prepared protest letter." (Prime Steel Mill vs. CIR, GR 249153, Sept. 12, 2022)
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AC Corp., CTA EB Case No. 2279 [CTA Case No. 8485], February 28, 2022) The Court of Tax Appeals may consider evidence attached to the motion for reconsideration. Taxpayer claims for refund for input taxes over its sales to "Microchip Technology Ireland" formerly registered as "ULC-Private Unlimited Company." In opposition, the BIR ...
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Meridien East Realty & Development Corporation (CTA EB No. 2287 [CTA Case No. 9130], July 14, 2022), the CTA En Banc rejected the retroactive application of RMC No. 20-2010, which overturned BIR Ruling No. DA-245-05. In the BIR ruling, the BIR initially opined that the transaction was not a sale subject to income tax, expanded …
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