The Court of Tax Appeals (CTA) has affirmed a February 2020 decision partially granting a tax credit certificate to Ayala Corp. worth P44.7 million over its excess creditable withholding tax for 2014. READ:
In a 19-page decision on May 18, the CTA full court denied the company’s petition for review to issue a new decision granting a tax credit certificate in the total amount of P62.4 million.
The commissioner of internal revenue claimed that Ayala Corp.’s evidence was not clear and convincing enough to justify its claim for refund. The tax court also junked the CIR petition to deny the company’s claim for a tax credit certificate for the same non-filing. ”Accordingly, the assailed amended decision has already attained finality and can no longer be questioned by the parties,” the ruling read. “Undoubtedly, therefore, the assailed amended decision is a ‘new or different’ decision, which was based on the Second Division’s reevaluation of the parties’ allegations and existing evidence that were not considered in the original assailed decision.”
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