TAX.8.20. Waterfront Cebu City Hotel v. CIR, CTA Case.

RULING: The CTA ruled that the assessment income tax of 1.5 million due to excess tax credits
would not give rise to deficiency income tax considering that it does not affect or pertain to income
or expense which would affect the company’s income tax due for 2006, and Waterfront’s 8 million
pesos overpayment in 2006is significantly higher that the company’s tax assessment.