This case has been cited 1 times or more.
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2007-04-24 |
SANDOVAL-GUTIERREZ, J. |
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| This Court has consistently reaffirmed its ruling in ABS-CBN Broadcasting Corp. in the later cases of Commissioner of Internal Revenue v. Borroughs, Ltd.,[12] Commissioner of Internal Revenue v. Mega Gen. Mdsg. Corp.[13] Commissioner of Internal Revenue v. Telefunken Semiconductor (Phils.) Inc.,[14] and Commissioner of Internal Revenue v. Court of Appeals.[15] The rule is that the BIR rulings have no retroactive effect where a grossly unfair deal would result to the prejudice of the taxpayer, as in this case. | |||||