G.R. No. 136975 - Commissioner of Internal Revenue vs. Hantex Trading Co., Inc.

Hantex Trading Co., Inc., a Philippine corporation manufacturing plastic products, imports synthetic resin and calcium carbonate and files Import Entries and Internal Revenue Declarations (Consumption Entries) with the Bureau of Customs (BOC).
In October 1989, EIIB received confidential information that Hantex understated its 1987 synthetic resin importations (claimed importations of ₱115,599,018 vs. declared ₱45,538,694.57). EIIB’s IIPO was tasked to audit and investigate under Mission Order No. 398-89 dated November 14, 1989.

IIPO subpoenaed Hantex’s president for books of accounts, importation records, income tax returns, and proof of tax payments; Hantex refused, citing prior audits by BIR.
IIPO obtained Profit & Loss Statements for 1987-1988 from the SEC and sought Consumption Entries from BOC, but originals were allegedly eaten by termites. Machine copies from an informer were used.
BOC Collection Chiefs Tomas and Danganan issued certifications listing entry numbers and release dates but did not authenticate amounts.

EIIB investigators (Flores, Dionela, Amoto) computed total 1987 importations at ₱105,716,527, uncovered ₱63,032,989.17 unreported sales, and recommended deficiency income tax of ₱41,916,937.78.
BIR inspectors Torres and Filamor corroborated unrecorded importations (₱70,661,694) and, on March 14, 1991, invited Hantex to a conference to present evidence. Hantex protested multiple investigations and invoked Section 235 NIRC (double jeopardy).
On April 15, 1991, BIR issued final Assessment Notices: deficiency income tax ₱13,414,226.40 and deficiency sales tax ₱14,752,903.25 (with surcharge and interest). Demand letters, warrant of distraint (Jan 21, 1992), and administrative hearings followed.

Hantex challenged admissibility of machine copies and Customs certifications; CTA admitted documents provisionally.
On December 11, 1997, CTA denied Hantex’s petition, ordered payment of ₱11,182,350.26 (income tax) and ₱12,660,382.46 (sales tax) with 20% interest.
On CA appeal, March 31, 2005, CA reversed CTA: assessments unlawful, based on unauthenticated hearsay (machine copies), violating best evidence rule and due process.

Does the petition for review under Rule 45 comply with Sections 4 and 5, Rule 7 of the Rules of Court?

Were the deficiency income and sales tax assessments for 1987 based on admissible, credible evidence and correct application of law (Section 16(b) NIRC vs. Rules of Evidence)?
Was Hantex’s right to due process observed in reliance on machine copies and Customs certifications?

If assessments are valid, what is the correct total amount of deficiency taxes due from Hantex for 1987?