TWENTY-SECOND DIVISION
[CA-G.R. SP No. 70908. January 23, 2008.]
LA FRUTERA, INC.,petitioner, vs. COMMISSIONER OF INTERNAL REVENUE,respondent.
D E C I S I O N
BORJA, R.V., J p:
This is a Petition for Review 1 of the March 22, 2002 Resolution of the Court of Tax Appeals, Quezon City, rendered in the exercise of its appellate jurisdiction in C.T.A. Case No. 5985, denying reconsideration of its January 16, 2002 Decision.
The Facts of the Case
Petitioner La Frutera, Inc., is a domestic corporation engaged in the business of producing and exporting cavendish bananas with principal place of business in Datu Paglas Estate, Barangay Digal, Buluan, Maguindanao, Autonomous Region of Muslim Mindanao. It is a duly registered VAT taxpayer with Tax Identification Number 004-397-647-VAT under BIR Certificate of Registration with RDO VAT Control No. 97-107-002104, dated April 1, 1997. Petitioner is also registered with the Board of Investments (BOI) with Certificate of Registration No. EP-014-97 issued on July 7, 1997.2
On August 19, 1999, petitioner filed with the Department of Finance, through its One-Stop-Shop Inter-Agency Tax Credit and Duty Drawback Center,...
