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COMMISSIONER OF INTERNAL REVENUE V. AICHI FORGING COMPANY OF ASIA, INC.,
G.R. No. 184823 October 6, 2010 Facts: On September 22, 2004, Aichi Forging filed a claim for tax refund for it's zero-rated sales with the Department of Finance One-Stop Inter-Agency Tax Credit and Duty Drawback Center. On the same day, they also filed a Petition for Review with the CTA. CTA partially granted the refund, but the Commission of Internal Revenue filed a Motion for Reconsideration stating that the claim was filed beyond the 2 years prescriptive period. However, CTA and CTA En Banc denied their motion. Issue: Whether or not the claim was filed within the prescriptive period under Sec. 112 (A) NIRC. Ruling: Yes, Sec. 31 Chapter VIII Book I of the Administrative Code of 1987 applies making 1 year = 12 months. The principle of Lex Posterioni Derogati Priori applies. Thus, since it is filed on exactly Sept. 30, 2004, filing is timely.
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