Commissioner of Internal Revenue v. Ramizo

FIFTEENTH DIVISION

[CA-G.R. SP NO. 115530. August 28, 2014.]

COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. Hon. EDWIN B. RAMIZO, in his capacity as Presiding Judge of the Regional Trial Court, National Capital Judicial Region, Pasay City, Branch 114, and PHILIPPINE INTERNATIONAL AIR TERMINALS, CO., INC. (PIATCO), respondents.

DECISION

CORALES, J p:

This is a Petition for Certiorari, Prohibition, and Mandamus 1 under Rule 65 of the Rules of Court seeking the reversal of the June 16, 2010 Order 2 of the Regional Trial Court (RTC), Branch 114, Pasay City in SCA No. R-PSY-10-02963-CV for prohibition with prayer for the issuance of temporary restraining order (TRO) and/or writ of preliminary injunction (WPI), entitled "Philippine International Air Terminals, Co., Inc. v. Commissioner of Internal Revenue" (the PIATCO Petition).

The Antecedents

On September 18, 2008, the Bureau of Internal Revenue (BIR) issued Letter of Authority (LOA) No. 00004421 for the examination of the books of accounts and other accounting records of Philippine International Air Terminals, Co., Inc. (PIATCO) for purposes of determining value-added tax (VAT) on its importations for the taxable year 2001. 3...

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