FACTS
Seagate Technology is a VAT registered entity. It filed for an administrative claim for refund of VAT input taxes in the amount of of P28,369,226.38.
The claim was not acted upon by the CIR, prompting Seagate to elevate the case to the Court of Tax Appeals. The CTA ruled that Seagate is entitled to the claimed refund. This was affirmed by the Court of Appeals.
However, the CA reduced the amount to P12,122,922.66, which represented the unutilized but substantiated input VAT paid on capital goods purchased for the period covering April 1, 1998 to June 30, 1999.
RULING
The Supreme Court ruled in favor of Seagate Technology.
Seagate is entitled to its claims. A mere administrative issuance, like a BIR regulation, cannot amend the law; the former cannot purport to do any more than interpret the latter.
To allow the additional requirement is to give unfettered discretion to those officials or agents who, without fluid consideration, are bent on denying a valid application.
Moreover, the State can never be estopped by the omissions, mistakes or errors of its officials or agents.
