4/7/2021
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[26] Id. at 427-444.
[27] AN ACT TO AMEND SECTION ONE OF ACT NUMBERED THIRTY-SEVEN HUNDRED
AND THIRTY-SIX, BY PROVIDING THAT THE PROVISIONS OF THE SAID ACT SHALL NOT
APPLY TO CASES INVOLVING LIABILITY FOR ANY TAX, DUTY, OR CHARGE COLLECTIBLE
UNDER ANY LAW ADMINISTERED BY THE BUREAU OF CUSTOMS OR THE BUREAU OF
INTERNAL REVENUE.
[28] Rollo, pp. 428-432.
[29] Id. at 474-491.
[30] AN ACT RECOGNIZING THE PRINCIPLE OF RECIPROCITY AS BASIS FOR THE
GRANT OF INCOME TAX EXEMPTIONS TO INTERNATIONAL CARRIERS AND
RATIONALIZING OTHER TAXES IMPOSED THEREON BY AMENDING SECTIONS 28(A)(3)
(a), 109, 118 AND 236 OF THE NATIONAL INTERNAL REVENUE CODE (NIRC), AS
AMENDED, AND FOR OTHER PURPOSES.
[31] Rollo, pp. 89-94.
[32] Id. at 94.
[33] Id. at 654-655.
[34] Id. at 658.
[35] Id. at 665.
[36] Id. at 674-700.
[37] Diaz, Jr. v. Valenciano, Jr., G.R. No. 209376, December 06, 2017, 848 SCRA 85,
96 (2017).
[38] 507 Phil. 94, 98 (2005).
[39] City of Lapu-Lapu v. PEZA, 748 Phil. 473, 512-513 (2014).
[40] 565 Phil. 766, 786-787 (2007).
[41] SEC. 4. Power of the Commissioner to Interpret Tax Laws and to Decide Tax Cases
- The power to interpret the provisions of this Code and other tax laws shall be under
the exclusive and original jurisdiction of the Commissioner, subject to review by the
Secretary of Finance.
The power to decide disputed assessments, refunds of internal revenue taxes, fees or
other charges, penalties imposed in relation thereto, or other matters arising under this
Code or other laws or portions thereof administered by the Bureau of Internal Revenue
is vested in the Commissioner, subject to the exclusive appellate jurisdiction of the
Court of Tax Appeals.
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65912
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