BAP Credit Bureau, Inc. v. Commissioner of Internal Revenue

EN BANC[C.T.A. EB CASE NO. 2095. September 3, 2020.](C.T.A. Case No. 9570)BAP CREDIT BUREAU, INC., petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.DECISIONBACORRO-VILLENA, J p:At bar is a Petition for Review 1 filed by petitioner BAP Credit Bureau, Inc. (petitioner/BAP) seeking the reversal and setting aside of the 08 April 2019 Decision 2 and 13 June 2019 Resolution 3 of the Court's Special Second Division. Both denied petitioner's claim for refund or issuance of tax credit certificate (TCC) pursuant to Section 229 4 of the National Internal Revenue Code (NIRC) of 1997, as amended. The dispositive portion of the assailed 08 April 2019 Decision reads: xxx xxx xxxWHEREFORE, premises considered, petitioner's claim for refund or issuance of tax credit certificate for alleged erroneously imposed and collected penalties in the filing of its Annual ITR for 2014 in the total amount of Php1,062,626.00 is DENIED for lack of merit.SO ORDERED.xxx xxx xxxThe Court's Special Second Division likewise denied petitioner's Motion for Reconsideration (MR) in its 13 June 2019 Resolution, viz.:xxx xxx xxxWHEREFORE, premises considered, petitioner's Motion for...