The Court’s Third Division, in a resolution dated March 15, 2023, and made public on July 18, Tuesday, directed the Makati City government to pay the its deficiency taxes of P1.05 billion for 1999 to 2001 and P217.8 million for 2002 to 2004.
This resulted in additional liabilities for the city government amounting to P2.9 billion and P435.6 million representing deficiency interests for 1999 to 2001 and 2002 to 2004, respectively. The CTA Second Division, in its December 16, 2009 decision, ruled in favor of the BIR and dismissed the petition for review filed by Makati.
Citing Section 204 of the National Internal Revenue Code of 1997, the tax court said that the approval of the National Evaluation Board is needed in cases of settlement where the basic tax involved exceeds P1 million, such as in the case of Makati City.
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