This case has been cited 1 times or more.
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2015-07-29 |
MENDOZA, J. |
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| In its Comment,[6] filed on July 28, 2014, ALPI made a survey of recent Court decisions that applied the San Roque case. It argued that in Republic v. GST Philippines,[7] CIR v. Visayas Geothermal,[8] Team Energy Corp. v. CIR,[9] Proctor & Gamble v. CIR,[10] and Visayas Geothermal v. CIR,[11] the Court applied BIR Ruling No. DA-489-03 because the judicial claims for VAT refund in these cases were filed within the interim period from December 10, 2003 to October 6, 2010; and yet, the taxpayer claimants did not expressly state that they relied or claimed to be misled by the said BIR Ruling. Thus, ALPI concluded there was no need to specifically invoke BIR Ruling No. DA-489-03 before a taxpayer could benefit from it. | |||||