G.R. No. 83383 - Solid State Multi-Products Corp. vs. Court of Appeals

The case involves consolidated petitions for review on certiorari under Rule 45 of the Rules of Court. It concerns a claim for refund or issuance of a tax credit certificate (TCC) filed by Deutsche Knowledge Services, Pte. Ltd. (DKS), a Philippine branch of a Singapore-based multinational company.
DKS is a registered VAT taxpayer in the Philippines and operates as a regional operating headquarter (ROHQ), providing various services such as general administration, business planning, procurement, finance advisory, marketing, technical support, and data processing.

On August 3, 2011, DKS filed with the Bureau of Internal Revenue (BIR) a claim for refund or issuance of a TCC amounting to PHP 34,107,284.30 representing unutilized input VAT on purchases related to zero-rated sales for the fourth quarter of 2009.
Breakdown of claimed input VAT includes purchases of capital goods (both exceeding and not exceeding PHP 1 million), domestic purchases of goods and services, and services rendered by non-residents.

DKS filed a judicial claim with the CTA on December 28, 2011.
The CTA Division, in its Decision dated September 16, 2014, partly granted DKS's claim, allowing a refund of PHP 15,859,091.24.
The CTA Division disallowed certain amounts for lack of supporting official receipts for zero-rated sales and for non-compliance with substantiation requirements under the Tax Code.
The Commissioner of Internal Revenue (CIR) moved for reconsideration, arguing the CTA had no jurisdiction as DKS did not submit the required documents for a valid administrative claim.
The CTA Division denied the CIR's motion and partly granted DKS's omnibus motion, modifying the refundable amount.
Both parties filed petitions for review before the CTA En Banc; the petitions were consolidated.

On February 17, 2016, the CTA En Banc denied both petitions for lack of merit.
The CTA En Banc affirmed the findings regarding zero-rated sales, disallowed sales due to missing or non-submitted official receipts, affirmed correct application of VAT rules on capital goods purchase, and agreed on the non-reopening of the trial.

The CIR argued that the CTA lacked jurisdiction because DKS failed to file a valid administrative claim due to lack of complete supporting documents.
DKS contended the CTA had jurisdiction and the failure to submit complete documents did not invalidate the claim.

G.R. Nos. 226548 & 227691:

Whether the CTA had jurisdiction over DKS's judicial claim for refund for the fourth quarter of 2009.

G.R. Nos. 226682 & 226683:

Whether the CTA En Banc properly disallowed certain sales covered by specified Official Receipts (OR Nos. 542 to 546, 601, 606, and 618) as zero-rated sales.
Whether the CTA En Banc properly disallowed input VAT on the purchase of capital goods exceeding PHP 1 million.
Whether the CTA En Banc properly applied the validated input VAT against output VAT to compute the refundable input VAT.
Whether the CTA En Banc properly denied DKS's request to reopen the trial to present supplemental evidence.