La Frutera, Inc. v. Commissioner of Internal Revenue

TWENTY-SECOND DIVISION[CA-G.R. SP No. 69378. April 24, 2006.]LA FRUTERA, INC., petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.D E C I S I O NVIDAL, M. D., J p:This is a Petition for Review under Rule 43 of the Revised Rules of Civil Procedure, from the Resolution 1 of the Court of Tax Appeals (CTA) in CTA Case Nos. 5898 and 5937 promulgated on 14 January 2002 partially granting the motion for reconsideration filed by LA FRUTERA, INC. (hereinafter Petitioner) and denying the COMMISSIONER OF INTERNAL REVENUE's (hereinafter Respondent) Motion for Reconsideration. Per the records, instant petition was filed on Our office on 21 February 2002 2 or prior to the effectivity of RA 9282 which expanded the jurisdiction of the CTA and elevated its rank to the level of a special collegiate court. Hence, this Court shall continue in the exercise of its jurisdiction in this case.The facts as summarized by the Court of Tax Appeals:Petitioner is a domestic corporation organized and existing under the laws of the Republic of the Philippines with principal place...