Commissioner of Internal Revenue v. Travellers International Hotel Group, Inc.

EN BANC[C.T.A. EB CASE NO. 2141. September 22, 2020.](C.T.A. Case No. 9275)COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. TRAVELLERS INTERNATIONAL HOTEL GROUP, INC., respondent.DECISIONMANAHAN, J p:This resolves the Petition for Review 1 filed by petitioner Commissioner of Internal Revenue (CIR) on October 16, 2019 pursuant to Section 3 (b), Rule 8 of the Revised Rules of the Court of Tax Appeals (RRCTA), as amended, 2 which prays for the reversal and setting aside of the Decision dated March 12, 2019 3 and the Resolution dated September 9, 2019 4 promulgated by the Special Third Division of the Court of Tax Appeals (CTA) in CTA Case No. 9275 entitled "Travellers International Hotel Group, Inc. vs. Commissioner of Internal Revenue," and the rendition instead of a new judgment ordering respondent to pay the total amount of Php2,923,190,960.33 for deficiency income tax including compromise penalty for taxable year 2011, as well as 25% and 50% surcharge, 20% deficiency and delinquency interest pursuant to Sections 248 and 249 of the 1997 NIRC, as amended, and 12% interest until full payment...