![]() In a letter, dated 08 August 1986, the BIR requested PNOC to settle its liability for taxes on the interests earned by its money placements with PNB and which PNB did not withhold. 1931, which took effect on 11 June 1984, withdrew all tax exemptions of government-owned and controlled corporations. Through his sworn statement, private respondent Savellano informed the BIR that PNB had failed to withhold the 15% final tax on interest earnings and/or yields from the money placements of PNOC with the said bank, in violation of Presidential Decree (P.D.) No. Savellano (Savellano) to the Bureau of Internal Revenue (BIR) on 24 June 1986. ![]() The Petitions before this Court originated from a sworn statement submitted by private respondent Tirso B. 29526, 4 respectively, which both affirmed the decision of the Court of Tax Appeals (CTA) in CTA Case No. This is a consolidation of two Petitions for Review on Certiorari filed by the Philippine National Oil Company (PNOC) 1 and the Philippine National Bank (PNB),< 2 assailing the decisions of the Court of Appeals in CA-G.R. ![]() SAVELLANO and COMMISSIONER OF INTERNAL REVENUE, Respondents. COURT OF APPEALS, COURT OF TAX APPEALS, TIRSO B. COURT OF APPEALS, THE COMMISSIONER OF INTERNAL REVENUE and TIRSO SAVELLANO, Respondents. ![]() PHILIPPINE NATIONAL OIL COMPANY, Petitioner, ![]()
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