SPECIAL FOURTEENTH DIVISION
[CA-G.R. SP NO. 69129. December 6, 2010.]
ASIANBANK CORPORATION (now known as GLOBAL BUSINESS BANK), petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.
DECISION
BALTAZAR-PADILLA, J p:
Pending resolution of this case, Republic Act 9282 1 was enacted on March 22, 2004 making the decisions of the Court of Tax Appeals (CTA) no longer appealable to this Court but directly to the Supreme Court. However, considering that the present case took place at the time when Republic Act No. 1125, otherwise known as An Act Creating the Court of Tax Appeals, was still in effect, this Court was vested with jurisdiction over the present petition.
This is a petition for review of the decision dated October 9, 2001 of the Court of Tax Appeals in CTA Case No. 6095 entitled "Asianbank Corporation vs. Commissioner of Internal Revenue" 2 denyingAsianbank Corporation's (now known asGlobal Business Bank, petitioner hereinafter) claim for tax refund on the ground of prescription.
FACTS
As culled from the decision of the CTA, the facts of the case are as follows:
"Petitioner is a corporation duly organized and existing...
