SPECIAL NINTH DIVISION
[CA-G.R. SP No. 73200. June 22, 2006.]
THE COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. UNITED INTERNATIONAL PICTURES AB, respondent.
D E C I S I O N
AREVALO-ZENAROSA,M., J p:
Before Us is a petition for review under Rule 43 of the 1997 Rules of Civil Procedure, seeking to reverse and set aside the Decision 1 dated June 5, 2002 rendered by the Court of Tax Appeals which cancelled and set aside the assessments issued against the respondent for deficiency internal revenue taxes in the total amount of P13,137,261.29 for taxable year 1994 as well as the preliminary collection letter dated August 14, 1998. Likewise assailed is the October 2, 2002 Resolution denying the motion for reconsideration.
The facts of the case as found by the Court of Tax Appeals are as follow:
Respondent is the Philippine Branch of United International Pictures AB, a corporation organized and existing under the laws of Sweden duly licensed to engage in business in the Philippines, with office address at the 4th Floor, Ramon Magsaysay Center, 1680 Roxas Boulevard, Malate, Manila.
On April 17,...
