[G.R. No. 184428 : November 23, 2011]
COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. SAN MIGUEL CORPORATION, RESPONDENT.
D E C I S I O N
VILLARAMA, JR., J.:
Elevated before us via a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, is the Decision1 of the Court of Tax Appeals (CTA) En Banc in C.T.A. EB No. 360 on a pure question of law, that is, whether the last paragraph of Section 1 of Bureau of Internal Revenue (BIR) Revenue Regulations No. 17-99 faithfully complies with the mandate of Section 143 of the Tax Reform Act of 1997.
The facts are undisputed:
Respondent San Miguel Corporation, a domestic corporation engaged in the manufacture and sale of fermented liquor, produces as one of its products Red Horse
The facts are undisputed:
Respondent San Miguel Corporation, a domestic corporation engaged in the manufacture and sale of fermented liquor, produces as one of its products Red Horse
