GENERAL PRINCIPLES ‘Scone and Limitations of Taxation Differentiate the tax exemption of non-atock, non-profit educational institutions: Dropriety educational institutions ne ryan giatas fe rorskck non ptt educaonl netiiong it eanaionad yo and excuse use of ther revenues aw assets for echacataral erry cuca! ston sti ott he ren rt of 1% compra ental earnings tp detctncy VAT on us‘exert trom come tax (Commissioner of Itomal Revenue v. Ateneo de Menta Univers, |s not subject to the payment’of franchises taxes. meritorious? No. The toca! has wth thor zed local government urls to impose a tax on businass anoying & franchise tax Nol "tera. Tile-» local government wat has the author to ness (Phaeive Long Diionee Telophone Company ie, v. CHy of Daven, et a G 149067, August 22, 200%), Distinguish withholding taxes,{he Municipal Board of the City of Manila enacted an Ordinance business taxes ‘Minstattarars, ngs prolucers ening Ducane int ety of Maral The (Ordinance, Allied Thread Go. Ine. laime exclusion from sake Ordina that'it'Goos. not maintain an oliee or branch fice im the City of Manila, Nowover, i admite tat t does business in the City. ‘dopand on the Iseation of tho fen, BUL attaches upon the place where the reapective Sal fe pertaced ond consummated ‘Shve Allied Thwaad seis its products in the City of Mani or, Ker & Company. Lis. cannot escape the tax labilty imposed by the Ordinance (Ale Inc v Cty Alayor of Manda, GR. No L-40296, Novernbor 21. 1988).tncome 90 top wee tna doliberanone “Accordingy, we see AO reason Wy an oe uyars (Sonane v Secretary Of France, GR. Ne, 184450, January. Doctrines in Taxation Double Taxation ‘The City of Manila assessed and collected taxes from A and Wholesalers, Distributors, or Dealers) and Section 17 (Tax on pectively, K also imposed additional taxes Subject to the Excise, Value-Added or Condition for renewal of their busines: funder Section 21, but thereaftor requested for tax ofedit oFNo. White as. rule, tues cannot be subject bro not eroditors and dablors of each other Shtormnton of the taxpayers Nabily i9 inartwAned wit the resolution rosusly oF logally colectod taxes under Sec, 229 of the NIFC. Hera, TPC fed 8k tv 1412 of the NIRC, whore the er cant Ard since it fs nota etoim for refund under Section 229 of te NI, the cere c one fs not on Issue. Thus, offsetting of taxes cannot be allowed 1 He | {Commiteoner of intemal Revenue v. Toledo Power company. G.R. Na, 19643 December Note: Sec. 112 of the Tax Code which refers to rotund of input tax altrbutable 19 29fe tere dered refund of an erronoous tax since refund of the same is 2 matter fright: estan of ald Uns ols under Soc 204 and Soc. 229 ofthe NIRC.i: What conte os 20 inpsnwe fcsgsions 3 conte NsiI tndadon » yehle coveersicn, beceae tes tte Sasa aa Masnas Conary’ nese’ Cocoa Costa, 12 PHIC Tal, 113) ‘one-half of the joked the same for being joed the tax proscribed on the gross income hw ‘ficiency, As counsel for X, what legal action would you take? ‘would contest the vai of retroactive appkeation oF the oew ereuar. The Tax Code provides jevocabon, modiicaton oF reversal of any of tho née and regulations ‘or any rulings promulgated by the CIR shall not be given retioactive applicaton it wil be prejudica tothe t the intrest of justice and far play rulings and circulars promulgated by the CIR: have: Ao: soptcaton where to 0 apply thar axpayers. who relied ino fengously compliod wi no lee ial of the BIR andfoal propery faut should undoubtedly pay the tax (Mania. Intemational AKpor Au (Paranaque. 6. NO. 155680, July 20, 2006) ‘Note The decision rendered in 1096 by the Supreme Court considening Mactan cebu Authony 08 COCC wos slteady reverse In 2018 by the Supreme Court in the ase of Capu Cay and jst le AAA, they a not both government instrumentalives exempted tax under Soe. 234 01 RA 7180, XYZ entered into an {ts President to soll ‘urportedly sold the property for P100 Same day to ORS for P200 Millon evidenced by Deeds of Absolute: to ORS, B ‘of he subjoct tax planning (onTAXATION Lal sxcome TAX mecome Atrenta Test ¥ Corporation engaged the services of the M Law Fim So 2010 to ater the: "a propery nec in fs benmness. For the lego! serwicen rendered hy 2018 Uh tem Corporation savy in 20% ¥ Coxporation claimed that aus eV vg Ue Beers suaae cous sly be claimed ae a Seauction fram gross wean 4 Hte BOTE ‘amount of tne expenne was etermined coy im BOTS. be Y's lait ene magnus fo the thwNon Resident Allon Engaged in Trade er Business 29. Y,a Japanese citizen, regular corresponding taxes. His cousin helped him prepare his Tax Return and claimed Seductions. The BIR, however, di not alow thie saying that the NIRE taxed Bis thou! deduction as a Non-Resident Citizen Not Engaged in Trade or Business. We rect? ‘i norsesisent akon Going businaee in 0 Phitgpines lor an agarenet thurs subject to 25 ‘No. Unaer tho Tax beefy bi al a yo petbeaforct afi orastnton mate locked St) ofroorat 31. J Comp grants all ts ergs18 No. In Sonano v. Sac. of Flaonce (2017), the Court ded thatthe prope ierpraon) tht timpones taxes only on the taxable income recetved in excess 6f te OR hot losa thet exemption ac such’ They romain MWe, ontted to exemption aa Income they ercaren cir ‘hie a MAWES Ray bo subjected to apbropnate tea, Wr OWS. ‘Soar iegstaove ntont to exempt BNE who eam accitonas icome on top ofthe Masa Interpretation apes n two ioe and against the governmant. (Sorane See. GR No 184480, January 24,2017) No. me benots fumsned by he employer ace or ts convenience oF is necessary Ke tunis, these tenets ave not gore on the pat of Ye omeployes. The fodgng, Dain & Frowged by X20 MA nto for te convarsence Of YZ. The 80k worth of fodging does linear dtl A Thus MA's oxo to pay eome tax sinc hei 8 MANU Income earned as an MVE26 Z Films Denmark, «corporation based in the Denmark, leased tte film Bjorn Legac Corporation in the Philippines tor showing. The SIR sough to collect the 25% tax im Nie but 2 Filme sought to reduce ta tax labilty by Invoking the deductions. ln Flim claim dedections? No The NIRC provides for special rates income from ‘pines. Given that te tx Is imposed income. 7 Fims carro! clam deductor sines gross teams taxation Gals Wi {ax payer witout considering the doductona. Thus, the 25% Isto be imposed on th total (Choritable institution‘No, 7042, doing business inciudes appointing representatives or dsibulors) fine forign corporation. (A Canaua ve: Commissoner oF intemal Revere Ge Ne. $1 2016) " Note: If he (AS maintains fights 10 and from the Phlippines, chal Be taxed at 2 54 of Grose Ph J, write TAC that co hot have fights 9 and irom We Philppnes but sams income. kom ai ‘etnies in te Phikppvnes wil bo tacod at tho rate of 30%. ‘Taxon Joint Venture 43 Corporation togetnor with Mr. Song, Mf. Ji, Me. Hyo, resident citizens, formed X Jolat to engage in the construction Business. X Joint Venture profited P100 Millon during Its first Sf operations. Me. Song, Ms, Me. Hye and Jd Corp. divided the earings equally, ' ‘engaged in food business and not in construction. Wi Iimpiteations.tax rotum wherein it claimed a8 advertising expense P10 Million, 80% of which was used for the protection of J's brand Wwanchie for ie The Commissioner disallowed said S0% and astessed the thus, not deductible. Decide. . ‘The Comensioner way correct To be deduetbe, an adverssing expense should not ony Ba bul also ordinary. Tho deductible expense mast meat two condone fat, rexconablenese of (reds actor ue trum cared esr he a coe oe eee Stor bytsess Ornoras ths pup trust bo onaldoed a apt expendtute tobe Spread aa tno tet onpece to eran ere pea ‘wonaure site fren inleses for In pobaananes Sf 68 DSEet Consired an rary expanse Gatuctio under the Tax Gabe, (Rw Gopal 143672 Ard 24,2003),w procowds of te insurance polices paid to. th (od are osc fem gross 1corna and Ie exept for te los of te, Pence a return ofc See. 2185/1). fvocate for ultural preservation in the Philippines. Without action on his ent of cash award in recognition of his cultural aéhievemont. 1 [ward excluded from t's gross income? No. The axcusicns from gros prmaay nr Ney eset feb gona tae hehe 2 Sumer bop:ng capital gain tan nthe tax paid by A correct? hie of tht bts should. be considered a ordinary income. The tan eset inch th lots ald formed part of A's cenial Business. Ths, ject capital gains tax (Toason, sv Lngad, GR. No. L-24248, July 31, 1974), 59 J voluntarily surrendered several properti56. X Co. Philippine corporation, sold through the local Bought 2 years aga. sold the shares lized a net gain of the tax lability ofthe X Co. co. able for stock 7 tax amounting to 10,000 which 6 4/2 of 1% oF 008 of {teling pron oF gross venue in money (P2 htnon) of te shares sok (TAX CODE, Soe. Note: if shares ccal stock exchange. 6% of the net capital gains (ek 'P100,000) and 10% of na ot carta pains (in excess of P'100,000) shal be imposbd. : iting of Tax Return ‘Six foreigners were employed In the US Naval Sase in tho PH. They refused to file their ‘tum claiming that they cannot be consivred resident aliens required to Me income ta ‘On the other hand, BIR contended60. ING Bank was assessed! by the Bift for deticiency withholding tax on e {090 amd {997.ING Bank inelots that the borius accruals In 1906 and 1907 wore withholding tax because the ‘were actually distributed only in the. Their accrual (rain 1007 and 1998) sthon the amounts were finally determined. 2 Discuss the nature of withholding tax on compensation bls the co! 2 2, Under the erase va Tho tax withhold ie intondos it apprawmate the tax due ofthe paves on The omployer Is required, by daducting and withholding the amount thereof Employee's compensation as when poss, ether netually or constuctvely. No. The obligation of the payorremployer to deduct and wanhols the related withholding tx anise the me the iicome vas paid or accrued or recorded as an expense in the inhichever comes frst ING Bark alrondy recognized a dofnte habiiy on its part cansieng, Secucted oe buninose expense fonso, thove wats alraody 8 cor ready abot or made ‘axes, but tis also oso Of tote tang an one69. ts 6 donation mortis causa to non-stock, non-profit educator tax? No. Although Art XIV, Secton 4(4 of the Consttiton proves that all grants, endowments. Contains used mclusty, Urey. and excusivoly Yor eaueational purposes eat Bo examet the forepang Consttutondl provson Te not eet execssing os I reques lellaive eneclment ‘certain conations tor Since Seo. 87 of NIRC does fot Include non-stock. feducalional instttions in he lat of exompt inabiutcns, donation to them is thus NOT EXEMPT, ‘onto tax Note: Soe. 101(0}3) of tho NR 4 that these donations are EXEMPT from donor's tax, X, single but head of tho fami, ‘15,2009. He loft the following properties and interests House and lot amy home) in Pasig 800,000 ‘Vacation house nnd itn Flori, USA. 1,500/000 Novotut ond nti Gow 000 34, ooo s NW'BEDA +Donors Tax. twiguel, a chizen and resident of Mexico, donated UsS1,000.60 wort of sickest eras Meaenn Corparati Mima som, mages, whet pete ie ‘utend, Mexico dove not impose ery tshaiot ‘Pestana ron artutus anaes of pope. Scent antaed lam's dowry excision? Wy oF ay SnludasatCnuncd ts the rao) veces a oder tbe exempt rom the Pipe ta tigers mort a. No. Under Section 10181) of tho RHR, dows oF gts mace ty a elizen oF resent ot Prapcines tw oxtn! 016 00 is oxen om Sonar ak Since MUO not onibed wo cama gowry exsion Tein eave of domes ade ty spouse who are citzene 0 reigons of the Pelppines. ‘ean claim separate exomoton in case of theW chikt's marriage (BIR Ruling No. 67-0039;71 Als. a candidata in the upcoming Senatorial lactions.B,baieving in the {2 imroguce much mended reforms Inthe county, costmbuied, Pat Eampuign choot of Ain eddtion, © purchosed taposiinay Cafits, ampaign materia that he miso conated fo'A for use in he campaign the nd campaign materials subject to doner’s tax? The snaner sunt atid, Seton 096)! he NING empty proves tat ay ‘orn tnd to any carcisata,peltea party or eaaliton of pat fe campaign By the ction Coda. as ane. On the athe hand. Sochon 13 af Repu Ast NO ties ht ny roaion tow foe ovr nating. ony con bn ea {anda or politcal erty of coalton of partes for campaign pupoven. dl repaid t te {Bacto (COUELEC) shat not sje ee ayer ay eT Eameaign conmlaons. of Pr 800,000 00 in each, tarpaulins, Cat, UmBrotas,Yeo. Undor Section 108. the plvasa “in the course of trad or Businoss” manne the regia 7 dureut of'a conmacal of an ezanome actvly. mneludhg trancastins nedental thereto, BY any pars Fogardioas of wnethor of not the person engaged therein Is a Non-siock, monocot Brive {respective of the disposition of net income ond whether of nett sete @xctuonly to Tamers {Sussts) or govarnmant enity Here, tie Rersan pao! car wos used a8 ped ol XC Slant and equiement. Hence, sale Ie considered as an incidental traacton which I (Qandanao i Geothermal Parinorshp vs. CIR, GR No. 198301, March 11, 2013) 76, G Condominium Corp. is an existing non-stock, non-profit association of unit owners. Te to reduce the association ues being collected from the unit owners, the Board ofperson oe tg om ra Vs fade Loss Tang [2048 rote The trarsior of goods erporied by tex-exomet persons of entity is ete tectnical imports Onserices MEDICARD, Health Mat Organization (HMO), primarily acte a6 an Intermediary between ‘mambers) and the healthcare providers for # ee. I'he modieal services of MEDIGARD. 80% of the fon to be paid to the healtneare providers and. ‘he reralning 20% c total amount actualy recelved by MEDIGARD rom ite members formed part of gross receipts and thus, subject to VAT? . 2007 relors 1 te tla amount of money a its riven oF to be performed fofCenter t0 pr ity. Wat kind of VAT fa lt subject to? Under Section 108 (8)0) ot Bank ie exoret trom or by a VAT registered oo ACall Conter operated by a domestic enterprise in Makat handles exclusively the 4 hotel chan which ae a Tocated In Nate arsaries, The carves re pol ter in US duly seourted for with she Banko Santa ng Plipnas, Dacore ine VAT lmplsa¥ont. Ut Seton 10810) tn hse neat ever Cos. he wn gc 2 VAT. Zerovated salen sees nudes vorveosrendoted io person engages Mt Bomnees ov Pepin ond to conadraton i pas! inoccptoie Ketag Satenay tp aceon erty al Sentral ng Pps8. XYZ company purchased from the national government a [t then, submitted to the BIR an inventory oral | s entitled to a transitional Input tax00. ABC Corporation. a VAT registered entity, is ‘of electricity to the NAPOCOR. After Bis ‘application, ABC fed ators the OF Input VAT payments. 15 days after and without filed » judicial claien with the CTA. I you are the CTA the jist clam of ABC Corpocation for ‘he fore on the pat ofthe Cl Socuments in support of93, A, a non-VAT registered person, is engaged in the business of n ‘of Manila, in 2016, A erroncously issund receipts to her clients 3 (TIN), followed with the word *VAT*, Upon, ‘top of percentage taxes, an amount equivalent to 25% sureha No. Under Sec. 113(0) the 1997 NIRC, the issuer of the ‘person who hos erroneously issued @ VAT receipt of Invoce Deteortaga taxes, be hablo to: a) the tax imposed in Sec. 106 ‘credit. and b) a tity poreent (60%) surcharge under Sec Ieortoet for the BIR to Impose ony 25% surchargo as th ‘50% aa penalty fr eronaous issuance of VAT recat. VAT registered taxpayer, handles‘used In its production of cigars and cigarettes. it clalmed ‘stommed teat tobacco and a specific tax on the finished form of double taxation, 4. Discuss the nature of excise taxos and its different kinds, bbls there double taxation? ‘2. Excise tax is a tax on the production, sala, or consumption taxes are essertaly tases 9 property because they 6 ‘manulactured or rotced in he Pritpieesregardless of the manner of Decide: Propertias transferred by moans of merger are not cof the NIRC, @ ‘stamp tax shall be ol whereby ny land, tanement105, The BIR issued a Prelim {or taxable year 1995. Five monthe later S| same deficiency taxes, After belng served, collection of taxes, §.¥ proses lve period. In this case, the assessment was released on January 31, 2013 "Year ponod to assess from the date of fing on February 1, 2010, Coneidanng that ‘uly mated {9 MB, ile prosumed thatthe assessment was mado din the Estates, inc. v. Commissioner of Internal Revenue. G.R. No. L-22492, September 6, 108.$ Corp. fled ts Annual income Tax Return for the taxable year 1999 February 17,2003, the PAN wos delivered, Subsoquentiy, on Ape 14,2008: trough registred ma, However, S Corp. ceniom having recaved the | ‘tuseas had presenbed, Decide, ‘i ‘Non an sess redo nn te prescrpive pais recap by the tea ‘athn sa pened. Butt must be caod tat De te does ot eaponee Wh Sipps cy ae mame, we Ga a {ator fe pove by congas eveonce et Se dad cae ns prcbardi Re shnad to thw WIR Yo show by eonraywtdonen Wa 8 Cor ssessment in the dus course of mail vi itis essential | Inasmuch as te|. Law. seedy prescribed as the protest later of XY2 Bank was a request fot ‘suspenc the running ol the preeenptve pad to eabeet (Bank of Ino Panepre Of iter! Revenue, GR No 16168 hy 92014), Waiver of Statue of Limitations 113 What does the now rule on walver provide? i; fortes ae Taowes ondTAXATION LAW. In this case, the imposition of the 20% doficiency interest on the daboeney income tax ‘surcharge, shat! acarue trom Aorl 15, 2007 through October 31, 2008 oF the winen the decency taxes shoul be peld, ut ful payment. The daingueney | ‘he folowing: () to the total efcency income tax ps deficiency Interest compte +1, 2008 unt ful payment, (6) and to the aseessed. dofcioncy amounts for VAT, ‘commencing Noverrser 1, 2008 unt the same are fly pad (uga2 ‘Commissioner of inlemar Revenue v. Lauigaz Philppines Corporation, CTA EB ‘Sopiombor 21,2915) ‘Note: Based on the provisions of RR No. 12.99, the inposiion of20 Pursuant to the finding of deficiency taxes due from ABC Corp. the Letter, Attar being served with a Warrant of Distraint andlor Levy to ‘ABC Corp. appealed to the BIR. ABC Corp. opted to wat for: failed to appeal tothe CTA within 30 days from the lapse of the 100 fact on the appeal by ABC Corp. within 180 days from appeal, wilSF X08 Law xpayer rst waive in wing his prvloge ofthe searecy ot vsrother general of special laws, which shall consttite 2s the CIR's autho Geposits Assuming that Mr Z complies with the said requsiles. partis may be allowed._— TAXATION LAW. ‘A Realty claimed for refund of its unutiized creditable, the disallowance of the amount of 200,000, due to the fact that, [Bin Form No. 2307, the same does not bear A Realty's Taxpayer Foquired that the CWT of BIR Form No, 2307 bear the TIN of th No. itis not necessary. As long as CWT Geary shows the inka ‘Qmount pad and the income tax withheld from that amount, 18468, Juno 22, 2016). 128, Me. 8 fled 9 claim for rotund with the CIR The two-yant {NO‘Cim nas yet to decide om the claim. Whai must Mr, B do Thclaim fr tofu reat bo fed withthe BIR and the‘as Gresit Corficates (TEC) representing the retund, th bois of the fact thatthe corporation Is under audi ty the there a valid justification for the BIR to withhold the issu No" Ofleting the amount of TCC against a potential tx Kail dre no yt faye’ Wie the amount fhe TCE facie yarto bo sotermined Bough th completion “withnold the TCC (Phitex Mining Corporation «} Corp. filed claim for rotund or tax credit for the excise petroleum products that it had sold to the V Corp,, an entity exempt The CTA Division and CTA En bane denied its claim for refund. Is or tax credit? ‘Yes In cases involving excise tax exemptions on petroleum Court has consistently held that i is the Corp. di not pass on to V Corp. the excisa taxes paid on tha later being exemet from indirect taxes. Hence, H Corp. Phi. tne. v. Commissioner of intemal Revenue, GR. NO. 188 Respondent PG-Phil, dectared dividends payable | PG-USA. amounting to P24.168.946.30, fromTAXATION LAW, fo rqure into the bank deposits of (1) a decedent to determine his gross estate: and (2) Tro'as fled an application for comeromse of his tax ably By reason of nancial incapacity ta habiity mae tn case a taxpayer files an application to compromise the payment of his tax financial positon demonstrates a clear inability to pay the tax ‘considered unless and unt he waives in wring his priviege under under other general or special laws, and such waiver shall constitute the: ‘inquire into the bank deposits of the taxpayer. 42_Wiat are BIR rulings? What is required to make a BIR ruling 'BIR rulings are administrative opinions issued by the Cc. TAXATION LAW. abich is @ trade oF commercial actly regularly engaged in 96 means traf, By is very ature, a condominium corporation is not engaged in| Gf hvelincod, nor tha procurement of profit fll within the scope of Concominium corporabon under the Condominium Act. Any profit that ‘ncisental (Yamane v. BA Lepanto Condominium Corporation, GIR. No.ss TAXATION LAW, No. the professional tax shall be paid only once for every taxable year and) ner in the city where he practices his profession or where he maintains his festence cannot require him to pay his professional taxes (Sec: 139. 149. The City Treasurer of Manila assessed petitioner © Bank other feos for taxable year 2007. On January 15, 2007, © | ‘protested the Imposition of business tax on the ground that tho City Treasurer did not resolve the protest by 083 xproperty tax exemptions previously granted fo oF ‘new is an agency ond ‘of realTAXATION LAW. 6 Corporation was assessed by the Municipal Treasurer of “deuinquencies. G Corporation questions the authority of the gevcsament and in collecting the sald taxes. What is G Corporation’ in the overt that the taxpayer questions the authority and power lstsessment, and of the treasurer to collect the foal property tax the only issue is the legality of vality of the assessment (aq Warranted (National Power Corporation v. Municipal Go Woverber 24, 2014) 157. The Munieipal Assessor of Pasig sont a notice of Nin a letter, Mr. N requested the ‘satiotiod, Mr. N filed with the RTS esements. The MA argue " niipal Assessor argueTAXATION LAW. Smportation 160. Whon does importation begin and when doos it end? Under Section 103 of the CMTA, importation begins when the ea Piligpine teritory with the intention to unload therein, Importation is d ‘ax0s and other charge due upon the goods have been paid or seq unless the goods are free ftom duties, taxes and ether charges and ‘Granted. or in case the goods are deorned tree of duties, taxes and ol loft ne junsdiction of te Bureau. aZeresorea! quontiies shail subject such vehicle to erature SSuron caver nity Nas been hatred o leased fr purpeees of eons Giiga As in ths case. ange the tek gamer does not Nave a ceria of froturnes that ho has net Yegehy engaged in Bw tacking business, Conditionally.Free Impertations: 165. Ms. Es a Filipino who went in USA for work and lived there for 1 ther work, she returned to the Philippines. She brought home with “which the bought at Hongkong. What is the tax implication? ‘The damond earrings are tubjoct 10 customs taxes and cuties, Sec: 600,( ‘personal and household effects belonging fo retuming residentsTAXATION LAW, no. Under Section 214 of tha CMTA, upon authorization of the Commlasioner, the Armed Forces of the Philippines and naional low enforgement warrantless search, seizure and arost. ln this ease, the P”inspectors ae | futhonty to conduct the search, seizure and aires 171, On May 16, 2005, ¥ Corporation imported 1000 kilos of ste! ingots the Bureau of Customs on the importation. On November 6, Irvestigated and asserted ¥ Corporation for deieleney aio, fe the No. Under Section 1000 of the CMTA jaw, the Bureau may only conduct ‘nication and nveskgation vstin tes years tom the tt Cantor lerance, in fue Cos, te Ingo se Buroau to assensdefiency das 200 ham 172_ Ms, P was charged inthe court with egal importation ‘agrecmem was reached with the Collector of CustomsThe Collector of Customs imposed excise tax om the importation of Tsssessment was based on a Letter issued by the CIR Interpreting Stetlon {4 include alkylate among the articles subject to customs cuties. P review with the CTA which assumed jurisdiction over the petlion on the controversy involves. a question on the propriety or soundagss of the Section 148 (e) of the NIRC whieh falls within the exclusive Juttadietion of thereof, particularly under the phrase “other matters arising under (the N ccorrectiy assume juriediction? 'No. The CTA has no jurisdiction to datermine the vaicy of a ruling fated ‘exorc's0 of ther quas lngelative powers to inlrprot ia laws. The phrase: {his Code” should be undersiood as pertning to those raters dewey “Greputod assessmon's, rofunds of intemal rovonuo (anos, fos of other tiation thereto” It cannot extend to evaluating the soundness ofthe {As the Cif’ interpretation of tax provision involves On exertae of Beromenwise, interna! Re Ne CTA wit not acquire juniscction over the elaim for refi oF rive v. Tokasayo Pils ine, CTA EB NO. 83S, October 18. 2072). Power to issue Injunetion 180. During the pendency of his case with the CTA, Mr. M sought the warrants of distraint andior levy and warrants of garnishment issued astets. The CTA granted the motion but Mr. M was required to either the deficiency taxes or post» bond. Can the CTA suspend tha: (Covered Cose) i Yes. The CTA has authority tots writ o restrain tha cl the law (Sps Pacquiao v. Court of Tex Appeals and Agr 18. 2016)[aggrieved by the decision of CTA Division, G Corp. filed a Petition for the SC. 1s the petition proper? fo. The SC 1s without junsciction to review decisions rendered by ‘ppalist jriscicton over wnich ie vested in the CTA en bane. A party ed Sta Divison ofthe CTA on a motion for reconsideration of ew Wal may fle B GTA@n banc (Duty Free Phiippines v. Bureau of Internal Revenue, GR Na. 1