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TOSHIBA INFORMATION EQUIPMENT v. CIR

This case has been cited 7 times or more.

	GR No. 202789 2015-06-22	CIR v. PUREGOLD DUTY FREE VELASCO JR., J.
Anent the second error raised by petitioner, it is worth noting that the CTA has ruled that the amnesty provision of RA 9399 covers the deficiency taxes assessed on Puregold and rejected the arguments raised on the matter by the CIR. It cannot be emphasized enough that the findings of the CTA merit utmost respect, considering that its function is by nature dedicated exclusively to the consideration of tax problems. The Court said as much in Toshiba v. Commissioner of Internal Revenue:[17]
	GR No. 179260 2014-04-02	CIR v. TEAM PEREZ, J.
It is apt to restate here the hornbook doctrine that the findings and conclusions of the CTA are accorded the highest respect and will not be lightly set aside. The CTA, by the very nature of its functions, is dedicated exclusively to the resolution of tax problems and has accordingly developed an expertise on the subject unless there has been an abusive or improvident exercise of authority.[24]
	GR No. 181692 2013-08-14	ADELAIDA SORIANO v. PEOPLE VILLARAMA, JR., J.
Fourth, both debts are liquidated and demandable. A debt is liquidated when the amount is known or is determinable by inspection of the terms and conditions of relevant documents.[19] There is no dispute that the value of the 398 sacks of corn grains is P85,607. As to Alagao's debt, we disagree with respondent People that the loan amount is only P40,000 since during pre-trial, Alagao herself admitted that she did not only receive P40,000 but P51,730 in the form of cash advances and fertilizers from petitioner. It is well settled that an admission made in a stipulation of facts at pre-trial by the parties is considered a judicial admission and, under the Rules of Court, requires no proof. Such admission may be controverted only by a showing that it was made through a palpable mistake or that no such admission was made.[20]
	GR No. 187485 2013-02-12	CIR v. SAN ROQUE POWER CORPORATION CARPIO, J.
The CTA Second Division partially granted Taganito's claim. In its Decision[25] dated 8 January 2010, the CTA Second Division found that Taganito complied with the requirements of Section 112(A) of RA 8424, as amended, to be entitled to a tax refund or credit of input VAT attributable to zero-rated or effectively zero-rated sales.[26]
	GR No. 168856 2012-08-29	EASTERN TELECOMMUNICATIONS PHILIPPINES v. CIR MENDOZA, J.
The Court finds no cogent reason to disturb the decision of the tax court. The CTA has developed an expertise on the subject of taxation because it is a specialized court dedicated exclusively to the study and resolution of tax problems.[30] As such, its findings of fact are accorded the highest respect and are generally conclusive upon this Court, in the absence of grave abuse of discretion or palpable error.[31] Its decisions shall not be lightly set aside on appeal, unless this Court finds that the questioned decision is not supported by sLibstantial evidence or there is a showing of abuse or improvident exercise of authority.[32]
	GR No. 170257 2011-09-07	RIZAL COMMERCIAL BANKING CORPORATION v. CIR MENDOZA, J.
As a final note, this Court has consistently held that findings and conclusions of the CTA shall be accorded the highest respect and shall be presumed valid, in the absence of any clear and convincing proof to the contrary.[36] The CTA, as a specialized court dedicated exclusively to the study and resolution of tax problems, has developed an expertise on the subject of taxation.[37] As such, its decisions shall not be lightly set aside on appeal, unless this Court finds that the questioned decision is not supported by substantial evidence or there is a showing of abuse or improvident exercise of authority on the part of the Tax Court.[38]
	GR No. 171742 2011-06-15	CIR v. MIRANT MENDOZA, J.
It is apt to restate here the time-honored doctrine that the findings and conclusions of the CTA are accorded the highest respect and will not be lightly set aside. The CTA, by the very nature of its functions, is dedicated exclusively to the resolution of tax problems and has accordingly developed an expertise on the subject unless there has been an abusive or improvident exercise of authority. [29] Citing Barcelon, Roxas Securities, Inc. (now known as UBP Securities, Inc.) v. Commissioner of Internal Revenue, [30] this Court in Toshiba Information Equipment (Phils.), Inc. v. Commissioner of Internal Revenue,[31] explicitly pronounced -