- Petitioner
- CIR
- Respondent
- Aichi Forging
- Citation
- G.R. No. 184823
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Del Castillo, J.
- Decided
- October 6, 2010
Summary
This case involves Aichi Forging Company's claim for VAT refund/credit of P3,891,123.82 for unutilized input VAT from July-September 2002. The Supreme Court established crucial precedents on VAT refund procedures: (1) the two-year prescriptive period for VAT refund claims under Section 112(A) NIRC is reckoned from the close of the taxable quarter when sales were made, not from tax payment date; (2) taxpayers must observe the mandatory 120-day waiting period for CIR action before filing judicial claims with CTA; and (3) simultaneous filing of administrative and judicial claims violates procedural due process requirements. While the administrative claim was timely filed, the premature judicial filing resulted in dismissal for lack of jurisdiction, emphasizing strict compliance with tax refund procedures.