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Accordingly, PSPC should pay the amount of Php1,384,721,993.00 representing the unpaid excise taxes and the corresponding VAT, exclusive of increments, on the importations of Alkylate from 2010 up to the present as declared in the twenty eight (28) import entries. Please be guided accordingly. Very truly yours, [SIGNED] KIM S. JACINTO-HENARES Commissioner of Internal Revenue [48] As may be gleaned from the first paragraphs of Document No. M-059-2012, the query relates to the particular transactions of PSPC and no other taxpayer, particularly with respect to its importations of alkylate from the year 2010 up to 2012. It also calls for an interpretation of whether alkylate can fall under the classification of "similar products of distillation" under Section 148 (e) of the Tax Code. Finally, it concludes with a determination of the taxability of PSPC's importations. Hence, although the query originated from the Collector and not the taxpayer in this case, the clarificatory/interpretative tenor of Document No. M-059-2012 relative to the PSPC's excise tax liability remains. As such, Document No. M-059-2012 is effectively a BIR Ruling issued against PSPC. b. The CTA has jurisdiction over challenges to BIR issuances such as Document No. M-059-2012. It is relevant to note that during the pendency of the proceedings, the issue anent the certiorari jurisdiction of the CTA over direct challenges to the validity of tax issuances was not yet definitively settled. Accordingly, the parties cited conflicting jurisprudence in their numerous pleadings before the CTA and this Court. However, on August 16, 2016, the Court En Banc promulgated Banco De Oro v. Republic of the Philippines ( Banco De Oro ), [49] wherein it was definitively settled that the CTA has jurisdiction over challenges to the validity of tax issuances. Notably, this overturned the previous doctrine in British American Tobacco v. Camacho ( British American Tobacco ), [50] which held that such jurisdiction lies in the regular courts, and not the CTA. To recount, in Banco De Oro , the Court held that the CTA's power to issue writs of certiorari in order to strike down tax issuances is inherent in the exercise of its appellate jurisdiction as derived from the CTA Law, which - being the special and later law - should take precedence over the general provisions of Batas Pambansa Bilang 129, viz .: This Court, however, declares that the Court of Tax Appeals may likewise take cognizance of cases directly challenging the constitutionality or validity of a tax law or regulation or administrative issuance (revenue orders, revenue memorandum circulars, rulings). Section 7 of Republic Act No. 1125, as amended, is explicit that, except for local taxes, appeals from the decisions of quasi-judicial agencies (Commissioner of Internal Revenue, Commissioner of Customs, Secretary of Finance, Central Board of Assessment Appeals, Secretary of Trade and Industry) on tax-related problems must be brought exclusively to th