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Court of Tax Appeals decisions
8,629 decisions · 1954–2026
2 decisions in June 1992
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- CITIBANK, N.A vs. Tt£ COMMISSIONER OF INTE.RNAL REVENlE, Respor.dent. X - - - - - - - - - - X D E C: 0 N Involved in the instant case is a claim fot~ refund or TAX credit of allegedly overpaid 10~ excise TAX on the sale of fc•reign exchar.ge, ir• the amount of P186,936.37. The facts as found by the Court are: 1. Petitioner, a foreign corporation duly licer•sed to er.gage ir1 banking activities in the Philippir.es, is authorized by the Central Bank to operate a Foreign Currency Deposit Unit or FCDU. Amohg the custornet~ s c•f petitioner's FCDU is the Philippine Long Distance and Telephone Company <PLOT>; 2. In its lettet~ to the Central Bar1k <CB> dated May 23, 1984 <Rollo, pp. 62- 63' J:•LDT requested that it be provided, through petitioner, with fot~ei gn exchar.ge 4.::>,... 0 t' in the amount of CTA Case No. 4069
- Philippine Long Distance Telephone Company and Private Export Funding Corporation vs. “ vs. ~ Commissioner of Internal Revenue CTA Case No. 4411