G.R. No. 178697 - COMMISSIONER OF INTERNAL REVENUE, VS. SONY PHILIPPINES, INC..D E C I S I O N - Supreme Court E-Library

Ruling

WHEREFORE, the petition for review is hereby PARTIALLY GRANTED. Respondent is ORDERED to CANCEL and WITHDRAW the deficiency assessment for value-added tax for 1997 for lack of merit. However, the deficiency assessments for expanded withholding tax and penalties for late remittance of internal revenue taxes are UPHELD. Accordingly, petitioner is DIRECTED to PAY the respondent the deficiency expanded withholding tax in the amount of P1,035,879.70 and the following penalties for late remittance of internal revenue taxes in the sum of P1,269,593.90: VAT on Royalty P 429,242.07 Withholding Tax on Royalty 831,428.20 EWT of Petitioner's Branches 8,923.63 Total P 1,269,593.90 Plus 20% delinquency interest from January 17, 2000 until fully paid pursuant to Section 249(C)(3) of the 1997 Tax Code. SO ORDERED.