Facts:

• The case involves the Commissioner of Internal Revenue (CIR) as the petitioner and Univation Motor Philippines, Inc. (formerly Nissan Motor Philippines, Inc.) as the respondent.
• On July 8, 2011, Univation Motor Philippines, Inc. filed its amended Annual Income Tax Return (ITR) for 2010, showing a total gross income of PHP 117,084,174.00 and an overpayment of income taxes amounting to PHP 26,103,898.52.
• The respondent opted to claim this overpayment through the issuance of a tax credit certificate.
• On March 12, 2012, the respondent filed an administrative claim with the Bureau of Internal Revenue (BIR) for the overpayment, which included prior year's excess credits and creditable withholding taxes accumulated during 2010.
• Since the BIR did not act on the administrative claim, the respondent filed a Petition for Review with the Court of Tax Appeals (CTA) on April 12, 2013.
• The CTA First Division partially granted the petition and ordered the CIR to issue a tax credit certificate for PHP 12,729,617.90.
• The CIR's Motion for Reconsideration was denied, prompting an appeal to the CTA En Banc, which affirmed the First Division's decision.
• The CIR then filed a petition with the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the CTA did not prematurely assume jurisdiction over the respondent's judicial claim for a tax refund or credit.
2. The Supreme Court affirmed the CTA En Banc's decision, ruling that th...(Unlock)

Ratio:

• The Supreme Court held that the two-year prescriptive period for filing a claim for a tax refund is crucial and starts from the date of filing the adjusted final tax return.
• In this case, the respondent filed its administrative claim and judicial claim within the two-year period, justifying its immediate resort to the court to avoid losing the right to seek judicial recourse.
• The Court found no violation of the doctrine of exhaustion of administrative remedies, as the law only requires that an administrative claim be filed prior to a judicial claim.
• The CTA has exclusive appellate jurisdiction over tax refund claims when the CIR fails to act on them, and the respondent ne...continue reading