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JurisprudenceG.R. No. 266641 -

G.R. No. 266641 - COMMISSIONER OF INTERNAL REVENUE, VS. SCRIPT2010, INC..DECISION - Supreme Court E-Library

En Banc

Cited Laws

RA 10963,
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TL;DR — Ruling

WHEREFORE , premises considered, the instant Petition for Review is PARTIALLY GRANTED . The assessments issued by [the CIR] against [Script] for the taxable year ended December 31, 2011 covering deficiency income tax, VAT, and EWT are AFFIRMED WITH MODIFICATIONS. Accordingly, [Script] is ORDERED TO PAY [the CIR] the aggregate amount of SIXTY-TWO MILLION EIGHT HUNDRED SEVENTY-NINE THOUSAND PESOS AND EIGHTY-SIX CENTAVOS ([PHP] 62,879,000.

Decision

Ruling

WHEREFORE , premises considered, the instant Petition for Review is PARTIALLY GRANTED . The assessments issued by [the CIR] against [Script] for the taxable year ended December 31, 2011 covering deficiency income tax, VAT, and EWT are AFFIRMED WITH MODIFICATIONS. Accordingly, [Script] is ORDERED TO PAY [the CIR] the aggregate amount of SIXTY-TWO MILLION EIGHT HUNDRED SEVENTY-NINE THOUSAND PESOS AND EIGHTY-SIX CENTAVOS ([PHP] 62,879,000.86) , inclusive of the 25% surcharge, 20% deficiency interest and 20% delinquency interest imposed under Sections 248(A)(3), 249(B) and (C) of the NIRC of 1997, as amended, respectively, computed until December 31, 2017, as follows: . . . . In addition, [Script] is ORDERED TO PAY delinquency interest at the rate of twelve percent (12%) on the total unpaid amount of [PHP] 44,469,495.99 as of July 31, 2015, as determined above, computed from January 1, 2018 until full payment thereof pursuant to Section 249(C) of the NIRC of 1997, as amended by Republic Act No. 10963, also known as Tax Reform for Acceleration and Inclusion (TRAIN) and as implemented by RR No. 21-2018. SO ORDERED.