UPS-Delbros Transport, Inc. v. Commissioner of Internal Revenue

EN BANC[C.T.A. EB CASE NO. 2026. November 19, 2020.](C.T.A. Case No. 9063)UPS-DELBROS TRANSPORT, INC., petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.[C.T.A. EB CASE NO. 2031. November 19, 2020.](C.T.A. Case No. 9063)COMMISSIONER OF INTERNAL REVENUE, petitioner, vs. UPS-DELBROS TRANSPORT, INC., respondent.DECISIONBACORRO-VILLENA, J p:At bar are two consolidated Petitions for Review 1 filed by UPS-Delbros Transport, Inc. (UPS-Delbros) and the Commissioner of Internal Revenue (CIR) assailing the Amended Decision of 19 October 2018 2 and the subsequent Resolution dated 21 February 2019, 3 respectively, of the Court's Special Third Division 4 in CTA Case No. 9063, entitled UPS-Delbros Transport, Inc. v. Commissioner of Internal Revenue. UPS-Delbros is a corporation duly organized and existing under the laws of the Philippines. It is a registered taxpayer with the Bureau of Internal Revenue (BIR), as evidenced by its Certificate of Registration dated 03 January 1994 and Taxpayer Identification No. (TIN) 002-743-457-000.The CIR, on the other hand, has the power to decide disputed assessments, refunds of internal revenue taxes, fees or other charges, penalties imposed in relation thereto or other matters...