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PHILIPPINE BANKING CORPORATION v. CIR

This case has been cited 6 times or more.

	GR No. 202789 2015-06-22	CIR v. PUREGOLD DUTY FREE VELASCO JR., J.
Furthermore, a tax amnesty, by nature, is designed to be a general grant of clemency and the only exceptions are those specifically mentioned. In Philippine Banking Corporation v. Commissioner of Internal Revenue,[25] this Court held that: A tax amnesty is a general pardon or the intentional overlooking by the State of its authority to impose penalties on persons otherwise guilty of violation of a tax law. It partakes of an absolute waiver by the government of its right to collect what is due it and to give tax evaders who wish to relent a chance to start with a clean slate.
	GR No. 165451 2014-12-03	LG ELECTRONICS PHILIPPINES v. CIR LEONEN, J.
In Philippine Banking Corporation (Now: Global Business Bank, Inc.), this court categorically found that "BIR's inclusion of 'issues and cases which were ruled by any court (even without finality) in favor of the BIR prior to amnesty availment of the taxpayer' as one of the exceptions . . . is misplaced."[54] This court said that: RA 9480 is specifically clear that the exceptions to the tax amnesty program include "tax cases subject of final and executory judgment by the courts." The present case has not become final and executory when Metrobank availed of the tax amnesty program.[55]
	GR No. 197515 2014-07-02	CIR v. UNITED SALVAGE PERALTA, J.
During the pendency of the proceedings, USTP moved to withdraw the aforesaid Petition because it availed of the benefits of the Tax Amnesty Program under Republic Act (R.A.) No. 9480.[9] Having complied with all the requirements therefor, the CTA-Special First Division partially granted the Motion to Withdraw and declared the issues on income tax, VAT and DST deficiencies closed and terminated in accordance with our pronouncement in Philippine Banking Corporation v. Commissioner of Internal Revenue.[10] Consequently, the case was submitted for decision covering the remaining issue on deficiency EWT and WTC, respectively, for taxable years 1992, 1994 and 1998.[11]
	GR No. 180390 2011-07-27	PRUDENTIAL BANK v. CIR DEL CASTILLO, J.
A certificate of deposit is defined as "a written acknowledgment by a bank or banker of the receipt of a sum of money on deposit which the bank or banker promises to pay to the depositor, to the order of the depositor, or to some other person or his order, whereby the relation of debtor and creditor between the bank and the depositor is created." [34]
	GR No. 172359 2009-10-02	CHINA BANKING CORPORATION v. CIR PERALTA, J.
The issue of whether or not Special Savings Deposits are subject to documentary stamp tax is not novel as the same has been the subject of this Court's ruling in International Exchange Bank v. Commissioner of Internal Revenue[32] (International) and Philippine Banking Corporation v. Commissioner of Internal Revenue[33](PBC).
	GR No. 178797 2009-08-04	METROPOLITAN BANK v. CIR CHICO-NAZARIO, J.
In a more recent case, Philippine Banking Corporation (Now: Global Business Bank, Inc.) v. Commissioner of Internal Revenue (PBC case),[19] the Court again considered the Special/Super Savings Deposit Account (SSDA) of PBC, evidenced by a passbook, as a certificate of deposit bearing interest on which DST under Section 180 of the NIRC could be imposed, citing both the BDO case and the IEB case.