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	GR Nos. 179045-46 2010-08-25	CIR v. SMART COMMUNICATION DEL CASTILLO, J.
In a Decision[19] dated February 23, 2006, the Second Division of the CTA upheld respondent's right, as a withholding agent, to file the claim for refund citing the cases of Commissioner of Internal Revenue v. Wander Philippines, Inc.,[20] Commissioner of Internal Revenue v. Procter & Gamble Philippine Manufacturing Corporation[21] and Commissioner of Internal Revenue v. The Court of Tax Appeals.[22]
	GR Nos. 171383 & 172379 2008-11-14	SILKAIR PTE. LTD. v. CIR CARPIO, J.
A "person liable for tax" has been held to be a "person subject to tax" and properly considered a "taxpayer." The terms "liable for tax" and "subject to tax" both connote a legal obligation or duty to pay a tax.[51]