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CIR v. CA

This case has been cited 6 times or more.

	GR No. 181136 2012-06-13	WESTERN MINDANAO POWER CORPORATION v. CIR SERENO, J.
In addition, it is notable that the CTA Second Division and the CTA En Banc, including Presiding Justice Acosta in his Concurring and Dissenting Opinion, both found that petitioner failed to sufficiently substantiate the existence of its effectively zero-rated sales to NPC for the 3rd and 4th quarters of taxable year 1999, as well as all four quarters of taxable year 2000. It must also be noted that the CTA is a highly specialized court dedicated exclusively to the study and consideration of revenue-related problems, in which it has necessarily developed an expertise.[21] Hence, its factual findings, when supported by substantial evidence, will not be disturbed on appeal.[22] We find no sufficient reason to exempt the present case from this general rule.
	GR NO. 158175 2007-10-18	PHILIPPINE NATIONAL BANK v. CIR QUISUMBING, J.
Now, petitioner avers that CTA rulings should not be disturbed, the CTA being a court of special jurisdiction. This, however, is only the general rule. CTA rulings will generally not be disturbed on appeal as long as the CTA does not commit gross error in the appreciation of facts.[30] But in this case, the CTA, like in China Banking Corporation, relied erroneously on Manila Jockey Club, Inc., thus, its pronouncement that the 20% FWT on interest income of banks should not form part of the taxable gross receipts subject to GRT cannot be sustained.
	GR No. 121666 2007-10-10	CIR v. MANILA ELECTRIC COMPANY CARPIO MORALES, J.
It is doctrinal that the factual findings of the Court of Tax Appeals, when supported by substantial evidence, will not be disturbed on appeal, unless it is shown that it committed gross error in the appreciation of facts.[24] Hence, as a matter of practice and principle, this Court will not set aside the conclusion reached by the said court, especially if affirmed by the Court of Appeals as in the present case. For by the nature of its functions, the tax court dedicates itself to the study and consideration of tax problems and necessarily develops expertise thereon, unless there has been an abuse or improvident exercise of authority on its part.[25] None such is appreciated by this Court, however.
	GR NO. 146941 2007-08-09	FILINVEST DEVELOPMENT CORPORATION v. CIR NACHURA, J.
It is settled that the factual findings of the CTA, as affirmed by the Court of Appeals, are entitled to the highest respect[16] and will not be disturbed on appeal unless it is shown that the lower courts committed gross error in the appreciation of facts.[17]
	GR Nos. 141104 & 148763 2007-06-08	ATLAS CONSOLIDATED MINING v. CIR CHICO-NAZARIO, J.
The distinction between a question of law and a question of fact is clear-cut. It has been held that "[t]here is a question of law in a given case when the doubt or difference arises as to what the law is on a certain state of facts; there is a question of fact when the doubt or difference arises as to the truth or falsehood of alleged facts."[42]