8/3/2019 cir v pnb

http://slidepdf.com/reader/full/cir-v-pnb 1/2

8/3/2019 cir v pnb

http://slidepdf.com/reader/full/cir-v-pnb 2/2

on the contrary PNB made an advance income tax payment made in response to a call of patriotic duty to help the national government.

 Therefore the tax credit sought by [respondent] is not simply a case of excess payment, but

rather for the application of the balance of advance income tax payment for subsequent

taxable years hence PNB’s claim for tax credit is NOT barred by the 2 yr prescriptive period.