Facts:

• CE Casecnan Water and Energy Company, Inc. (CE Casecnan) is engaged in the design, development, construction, and operation of hydro-electric power plants.
• CE Casecnan filed its quarterly VAT returns for the first to fourth quarters of 2006 and had unutilized input VAT credits.
• CE Casecnan filed an administrative claim for refund or tax credit for the excess input VAT.
• The Commissioner of Internal Revenue did not act on the claim.
• CE Casecnan filed a Petition for Review with the Court of Tax Appeals (CTA).
• The CTA dismissed the petition for being filed beyond the 30-day period prescribed by Section 112(c) of the National Internal Revenue Code (NIRC).

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the denial of CE Casecnan's claim for refund.
• The Court held that the 30-day period under Section 112(c) of the NIRC is mandatory and jurisdictional.
• Compliance with the prescribed period is necessary for the Court of Tax Appeals to acquire jurisdiction over the claim.
• The Court emphasized that the ruling in San Roque Power Corporation v. Commissioner of Internal...(Unlock)

Ratio:

• The Court ruled that the 30-day period under Section 112(c) of the NIRC is mandatory and jurisdictional.
• Compliance with the prescribed period is necessary for the Court of Tax Appeals to acquire jurisdiction over the claim.
• The Court clarified that the ruling in San Roque Power Corporation v. Commi...continue reading