FORT BONIFACIO DEVELOPMENT CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE and REVENUE DISTRICT OFFICER, REVENUE DISTRICT NO. 44, TAGUIG & PATEROS, BUREAU OF INTERNAL REVENUE, respondents.

FIRST DIVISION[CA-G.R. SP No. 76540. April 30, 2007.]FORT BONIFACIO DEVELOPMENT CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE and REVENUE DISTRICT OFFICER, REVENUE DISTRICT NO. 44, TAGUIG & PATEROS, BUREAU OF INTERNAL REVENUE, respondents.D E C I S I O NDIMAAMPAO, J p:This is a Petition for Review assailing the Resolution 1 dated 28 March 2003 of the Court of Tax Appeals which denied petitioner's claim for tax refund amounting to P77,151,020,46. Caught in this legal quagmire is petitioner Fort Bonifacio Development Corporation, a domestic corporation engaged in real estate business. Forty five percent (45%) of petitioner's issued and outstanding capital stock is owned by the Bases Conversion Development Authority (BCDA), a wholly owned government corporation created pursuant to Republic Act No. 7227; 2 while the remaining fifty five percent (55%) is owned by Bonifacio Land Corporation, a consortium of private domestic corporations. 3In May 1996, petitioner started to develop parcels of land within a newtown development area known as the Fort Bonifacio Global City ("Global City"), located within Fort Bonifacio, Taguig, Metro Manila. By October...