PMFC V.

CIR

Facts:

PMFC is a corporation organized and existing uder laws of the Philippines.The books of accounts of
PMFC pertaining to 1996 were examined by the CIR for deficiency income, value – added tax and
withholding tax liabilities.

Consequently, as a result of the investigation, assessment notices were issued against PMFC,and thereof
demanding payment of said tax assessments.

PMFC filed a protest letter against the said deficiency tax assessments.

CIR rendered a decision on the disputed assessments wherein it reduced the deficiency tax liabilities of
PMFC from 9 million to 3 million.

PMFC filed a petition for review