This case has been cited 1 times or more.
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2014-02-05 |
REYES, J. |
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| Finally, even if TSC was able to substantiate, through the documents it submitted, that it is indeed entitled to a refund/tax credit of its unutilized input VAT for the taxable year 2000, its claim would still have to be denied. "Tax refunds are in the nature of tax exemptions, and are to be construed strictissimi juris against the entity claiming the same."[28] "The taxpayer is charged with the heavy burden of proving that he has complied with and satisfied all the statutory and administrative requirements to be entitled to the tax refund."[29] TSC, in prematurely filing a petition for review with the CTA, failed to comply with the 120-day mandatory period under Section 112(C) of the NIRC. Thus, TSC's claim for refund/tax credit of its unutilized input VAT should be denied. | |||||