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HITACHI GLOBAL STORAGE TECHNOLOGIES PHILIPPINES CORP. v. CIR

This case has been cited 3 times or more.

	GR No. 187485 2013-10-08	CIR v. SAN ROQUE POWER CORPORATION CARPIO, J.
Even this Court in resolving claims for refund of input VAT paid after January 1, 1998 recognized the effectivity of RR 7-95 in interpreting the provisions of the 1997 Tax Code. In Hitachi Global Storage Technologies Philippines, Corp. v. Commissioner of Internal Revenue,[19] this Court, speaking through Justice Carpio, sustained the denial of an application for refund of input VAT for the four taxable quarters of 1999 on the ground of petitioner-taxpayer's failure to comply with the provisions of RR 7-95. Citing Panasonic v. Commissioner of Internal Revenue,[20] We explained that RR 7-95 gained the status of a legislative act that binds the taxpayers and this Court:On 4 August 2000, Hitachi filed an administrative claim for refund or issuance of a tax credit certificate before the BIR. The claim involved P25,023,471.84 representing excess input VAT attributable to Hitachi's zero-rated export sales for the four taxable quarters of 1999.
	GR No. 168856 2012-08-29	EASTERN TELECOMMUNICATIONS PHILIPPINES v. CIR MENDOZA, J.
The Court finds no cogent reason to disturb the decision of the tax court. The CTA has developed an expertise on the subject of taxation because it is a specialized court dedicated exclusively to the study and resolution of tax problems.[30] As such, its findings of fact are accorded the highest respect and are generally conclusive upon this Court, in the absence of grave abuse of discretion or palpable error.[31] Its decisions shall not be lightly set aside on appeal, unless this Court finds that the questioned decision is not supported by sLibstantial evidence or there is a showing of abuse or improvident exercise of authority.[32]
	GR No. 179961 2011-01-31	KEPCO PHILIPPINES CORPORATION v. CIR MENDOZA, J.
Indeed, in a string of recent decisions on this matter, to wit: Panasonic Communications Imaging Corporation of the Philippines v. Commissioner of Internal Revenue,[19] J.R.A. Philippines, Inc. v. Commissioner of Internal Revenue,[20] Hitachi Global Storage Technologies Philippines Corp. (formerly Hitachi Computer Products (Asia) Corporations) v. Commissioner of Internal Revenue,[21] and Kepco Philippines Corporation v. Commissioner of Internal Revenue,[22] this Court has consistently held that failure to print the word "zero-rated" on the invoices or receipts is fatal to a claim for refund or credit of input VAT on zero-rated sales.