Kabalikat Para Sa Maunlad Na Buhay v. Revenue

INTING, J.:

Before the Court are consolidated Petitions for Review on Certiorari under Rule 45 of the Rules of Court: 1. G.R. Nos. 217530-311 and 217536-372 filed by Kabalikat Para Sa Maunlad Na Buhay, Inc. (Kabalikat); and 2. G.R. No. 2178023 filed by the Commissioner of Internal Revenue (CIR), through the Office of the Solicitor General (OSG).

These petitions assail the Court of Tax Appeals (CTA) En Banc's Resolutions dated January 13, 20154 and March 25, 20155 in CTA EB Nos. 1238 and 1239. The Facts Kabalikat is a non-stock, non-profit civic organization.6 The Bureau of Internal Revenue (BIR) confirmed Kabalikat's status as a civic organization, as well as its exemption from the payment of income tax, through BIR Ruling No. S-30-071-20017 dated October 8, 2001. In 2006, pursuant to Republic Act No. 8425 or the "Social Reform and Poverty Alleviation Act,"

Kabalikat amended its Articles of Incorporation8 to expressly provide micro-financing services to "small, cottage-scale, micro-entrepreneurial poor and the disadvantaged such as farmers, fishermen, women, tribal minorities, urban poor and other similar sectors."9 BIR, through Regional Director Jaime B. Santiago, issued Preliminary Assessment Notices (PAN) against Kabalikat in relation to unpaid taxes for the taxable year 2006 amounting to P78,380,415.03, computed as follows: