The Court of Tax Appeals (CTA) has ordered the Bureau of Internal Revenue (BIR) to refund Casas+Architects, a Makati City-based firm providing architectural services, P11.6 million representing excess and unutilized creditable withholding taxes in 2015. The order was contained in the CTA’s July 4, 2023 full court decision that affirmed the ruling handed down by its first division on June 17, 2021. The first division’s ruling was appealed by the BIR “for lack of factual and legal bases and/or lack of jurisdiction.” It claimed there was an error in declaring that Casas+Architects' annual income tax return (ITR) for 2014 is sufficient to prove its "Prior Year's Excess Credits" in the amount of P2,831,752. There were also issues raised on the declaration of firm’s claim for a tax refund for 2015 since it was filed out of time, it said. Case records showed that on April 15, 2016, Casas+Architects filed with the Makati City’s BIR office its annual income tax return (ITR) with net sales of P160.4 million. After all deductions, it said its income tax due was P5.18. But the firm said it had a total of P24.6 million in creditable tax withheld from BIR Form No. 2307.  Thus, it said it had a net overpayment of P19.4 million and sought a refund or issuance of tax credits. When the BIR did not heed its plea, the firm elevated the issue before the CTA. Instead of the P19.4 million pleaded for refund or tax credits, the CTA’s first division ordered BIR to refund P11.6 million. With the denial of its motion for reconsideration, the BIR elevated the case to the CTA’s full court. The CTA as a full court ruled that BIR’s petition lacked merit.  It said the taxpayer’s claim for excess credits is allowed and that the plea filed by Casas+Architects was timely filed. "After a careful examination and consideration of the facts, issues, and arguments presented by the parties, the Court En Banc finds that petitioner (BIR) failed to raise any new or substantial matter, let alone any compelling reason to warrant the modification, much less reversal of the assailed Decision and Resolution," the CTA’s full court decision read. The decision was written by Associat Justice Lanee S. Cui-David with the concurrence of Presiding Justice Roman G. Del Rosario and Associate Justices Ma. Belen M. Ringpis-Liban, Catherine T. Manahan, Jean Marie A. Bacorro-Villena, Maria Rowena Modesto-San Pedro, Marian Ivy F. Reyes-Fajardo, and Corazon G. Ferrer-Flores.