Cited Laws
TL;DR — Ruling
WHEREFORE , premises considered, the Petition for Review is hereby DENIED . Formal Letter of Demand issued by Revenue Region No. 9, San Pablo City, covering the period June 1, 2004 to May 31, 2005 is hereby AFFIRMED with MODIFICATION . The compromise penalties in the total amount of P90,000 are hereby CANCELLED .
WHEREFORE , premises considered, the Petition for Review is hereby DENIED . Formal Letter of Demand issued by Revenue Region No. 9, San Pablo City, covering the period June 1, 2004 to May 31, 2005 is hereby AFFIRMED with MODIFICATION . The compromise penalties in the total amount of P90,000 are hereby CANCELLED . Accordingly, [DLSLI] is ORDERED to PAY (CIR] the amount of Php6,966,280.73, inclusive of the 25% surcharge imposed under Section 248(A)(3) of the National Internal Revenue Code of 1997, as amended, broken down as follows: TYPE OF TAX BASIC TAX 25% SURCHARGE TOTAL Income Tax Php3,539,420.73 Php884,855.18 Php4,424,275.92 Value-Added Tax 1,106,068.98 276,517.24 1,382,586.22 Expanded Withholding Tax 927,534.87 231,883.72 1,159,418.59 Total Php 5,573,024.58 Php 1,393,256.15 Php 6,966,280.73 In addition, [DLSLI] shall be liable to pay: (a) Deficiency interest at the rate of twenty percent (20%) per annum on the basic deficiency income tax, value-added tax, and expanded withholding tax computed from the dates indicated below until full payment thereof pursuant to Section 249(B) of the NIRC of 1997, as amended; Tax Type Basic Tax Deficiency Interest Computed from Income Tax Php3,539,420.73 September 15, 2005 Value-Added Tax 1,106,068.98 June 27, 2005 Expanded Withholding Tax 927,534.87 June 15, 2005 (b) Delinquency interest at the rate of 20% per annum on the total amount of Php6,966,280.73 and on the 20% deficiency interest which have accrued as afore-stated in (a), computed from October 13, 2011 until full payment thereof pursuant to Section 249(C) of the NIRC of 1997, as amended. SO ORDERED.