CIR v Mirant Pagbilao Corp.; G.R. No. 172129; 12 Sep 2008
FACTS: Respondent secured the services of Mitsubishi Corporation of Japan but opted not to immediately pay the VAT component of the progress billings from Mitsubishi for the period covering 07 April 1993 to 06 September 1996. It was only on 14 April 1998 when respondent paid Mitsubishi the VAT component for said progress billings. On 25 August 1998, it filed its quarterly VAT return for the second quarter of 1998 where it reflected an input VAT, including that which was paid on 14 April 1998. On 20 December 1999, respondent filed an administrative claim for refund of unutilized input VAT.…