This case has been cited 1 times or more.
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2006-10-16 |
CHICO-NAZARIO, J. |
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| In his Petition and Memorandum before this Court, the BIR Commissioner made no attempt to provide reasonable explanation for his failure to raise before the CTA the issue of MPC being a public utility subject to franchise tax rather than VAT. The BIR Commissioner argues, in a singular paragraph in his Petition,[18] subsequently reproduced in his Memorandum,[19] that the Court of Appeals should have taken cognizance of the said issue, although it was raised for the first time on appeal, entirely on the basis of this Court's ruling in Sy v. Court of Appeals.[20] He contends that - | |||||