COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. COURT OF TAX APPEALS THIRD DIVISION AND CITYSUPER, INCORPORATED, RESPONDENTS.
- G.R. Number: G.R. No. 239464
- Promulgated: 2021-05-10
Keywords
Section 228 National Internal Revenue Code, Section 203 National Internal Revenue Code, Section 222(b) National Internal Revenue Code, Revenue Memorandum Order No. 20-90, Revenue Delegation Authority Order No. 05-01, Revenue Regulations No. 18-2013, Section 7 Republic Act No. 9282, Rule 65 Rules of Court, Rule 132 Section 20 Rules of Court, Tijam v. Sibonghanoy, Doctrine of Estoppel by Laches, Tax Assessment, Tax Deficiency, Waiver of Defense of Prescription, Court of Tax Appeals Jurisdiction, Jurisdiction over Subject Matter, Interlocutory Orders, Final and Executory Judgment, Valid Protest, Prescription Period