G.R. Nos. 199729-30 - MANILA BANKERS' LIFE INSURANCE CORPORATION, VS. COMMISSIONER OF INTERNAL REVENUE.[G.R. Nos. 199732-33] COMMISSIONER OF INTERNAL REVENUE, VS. MANILA BANKERS' LIFE INSURANCE CORPORATION.D E C I S I O N - Supreme Court E-Library

Ruling

WHEREFORE , in view of the foregoing considerations, the consolidated Petitions for Review seeking the cancellation of respondent's assessments for; deficiency Minimum Corporate Income Tax (MCIT) and deficiency Documentary Stamp Tax (DST) and increments for taxable year 2001 in CTA Case No. 7266 ; deficiency DST and increments for taxable year 2002 in CTA Case No. 7324 ; and deficiency DST and increments for taxable year 2003 in CTA Case No. 7378 are DENIED . The Formal Assessment Notices issued by respondent against petitioner covering deficiency MCIT for taxable year 2001 and deficiency DST for taxable years 2001, 2002 and 2003 are hereby AFFIRMED WITH MODIFICATIONS . The compromise penalties are CANCELLED . However, a twenty-five percent (25%) surcharge is imposed, pursuant to Section 248(A) of the NIRC of 1997. Accordingly, petitioner is hereby ORDERED TO PAY respondent the amount of FOURTEEN MILLION SIXTY-THREE THOUSAND SIX HUNDRED SEVEN PESOS AND 51/100 (P14,063,607.51) , representing its deficiency MCIT for taxable year 2001 and deficiency DST for taxable years 2001, 2002, and 2003, inclusive of increments, computed as follows: 2001 2002 2003 Grand Total MCIT Basic MCIT Due P30,162.56 25% Surcharge 7,540.64 20% Interest 14,076.86 P51,780.06 P51,780.06 DST Basic DST Due P4,841,002.50 P1,764,579.41 P1,689,709.49 25% Surcharge 1,210,250.63 441,144.85 422,427.37 20% Interest 2,485,370.68 763,848.53 393,493.99 P8,536,623.81 P2,969,572.79 P2,505,630.85 P14,011,827.45 Total Amount Due P8,588,403.87 P2,969,572.79 P2,505,630.85 P14,063,607.51 In addition, petitioner is hereby ORDERED TO PAY twenty percent (20%) delinquency interest on P8,588,403.87, representing the total amount due for taxable year 2001, computed from August 11, 2004; as well as on the P2,969,572.79 and P2,505,630.85 total amounts due for taxable years 2002 and 2003, respectively, computed from March 5, 2005 until full payment thereof: pursuant to Section 249(C)(3) of the NIRC of 1997. SO ORDERED.