Toshiba Information Equipment (Phils.), Inc. v. Commissioner of Internal Revenue

[C.T.A. CASE NO. 5593. March 10, 2000.] TOSHIBA INFORMATION EQUIPMENT (PHILS.) INC. , petitioner , vs . COMMISSIONER OF INTERNAL REVENUE , respondent . D E C I S I O N This is a petition seeking for the refund or issuance of a tax credit certificate in the amount of P19,338,422.07, representing unutilized input taxes paid by Petitioner on its local purchases of capital goods and services for the first and second quarters of 1996. Petitioner is a domestic corporation duly organized and existing under and by virtue of Philippine laws, with principal office at 103 East Main Ave. Extension, SEPZ, Phase III, Laguna Technopark, Bian, Laguna (Exh. A). It is registered with the Philippine Economic Zone Authority (PEZA) as an Ecozone Export Enterprise under Certificate of Registration No. 95-99 (Exh. B) as well as with the Bureau of Internal Revenue (BIR) as a value-added tax (VAT) taxpayer under VAT Registration No. 95-570-001544 (Exh. C). Petitioner is principally engaged in the business of manufacturing and exporting electrical and mechanical machinery, equipment, systems, accessories, parts, components, materials and goods of all kinds, including without limitation to those relating to office automation and information technology and including all types of computer based equipment and systems, computer hardware and software of all kinds, including but not limited to HDD, CD-ROM and personal computer printed circuit board. For the period January 1, 1996 to June 30, 1996, Petitioner filed its first and second quarter VAT returns, reflecting input taxes amounting to P13,118,542.00 and P5,128,761.94, respectively, or a total of P18,247,303.94. As Petitioner allegedly has not yet engaged in any business activity or transaction for which it may be liable for output VAT, the input taxes during the aforesaid period were not utilized as there is no output VAT against which the same may be credited. Thus, on March 27, 1998, in accordance with Section 112 (b) [formerly Sec. 106(b)] of the Tax Code, which provides: "Sec. 112. . . . (b) Capital goods . A VAT-registered person may apply for the issuance of a tax credit certificate or refund of input taxes paid on capital goods imported or locally purchased, to the extent that such input taxes have not been applied against output taxes. The application may be made only within two (2) years after the close of the taxable quarter when the importation or purchase was made," and pursuant to Revenue Audit Memorandum Order No. 2-93, Petitioner filed with the One-Stop-Shop Inter-Agency Tax Credit and Duty Drawback Center of the Department of Finance (CENTER-DOF) two separate applications for tax credit/refund of its unutilized VAT input payments: the first, from January 1, 1996 to March 31, 1996 in the amount of P14,176,601.28 (Exhs. L, M) and the second, from April 1, 1996 to June 30, 1996 amounting to P5,161,820.79 (Exhs. N, O), or a total of P19,338,442.07. As there was no immediate action on the part of CENTER-DOF and the two-year prescriptive period under Sec. 230 of the Tax Code was about to lapse, the instant petition for review was filed on March 31, 1998 and subsequently amended on November 24, 1998 in order to conform to the evidence presented. In his answer, Respondent raised the following Special and Affirmative Defenses: llcd "5. Assuming without admitting that petitioner filed a claim for refund/tax credit, the same is subject to investigation by the Bureau of Internal Revenue. LexLib 6. Taxes are presumed to have been collected in accordance with law. Hence, petitioner must prove that the taxes sought to be refunded were erroneously or illegally collected. 7. Petitioner must prove the allegations supporting its entitlement to a refund. 8. Petitioner must show that it has complied with the provisions of Sections 204(c) and 229 of the 1997 Tax Code on the filing of a written claim for refund within two (2) years from the date of payment of the tax. llcd 9. Claims for refund of taxes are construed strictly against claimants, the same being in the nature of an exemption from taxation." LibLex The sole issue We are tasked to resolve is whether or not Petitioner is entitled to the relief sought on the basis of the evidence presented. llcd To support its claim, Petitioner offered as evidence the following exhibits: Exhibits Description A 13-page copy of SEC Reg. No. AS095 006536 issued to Toshiba Information Equipment (Phils.), Inc. including its Articles of Incorporation. B PEZA Certificate of Registration No. 95-99 issued to Toshiba Information Equipment (Phils.), Inc. C BIR Certificate of Registration No. 95-570 001544 dated Dec. 29, 1995 issued to Toshiba Information Equipment (Phils.), Inc. D, E, F, G Value-Added Tax Returns for the first, second, third and fourth quarters of 1996 filed by Petitioner on April 22, 1996, July 22, 1996, October 21, 1996 and January 20, 1997, respectively H, I, J, K Value -Added Tax Returns for the first, second, third and fourth quarters of 1997 filed by Petitioner on April 14, 1997, July 21, 1997, October 20, 1997 and January 20, 1998, respectively L DOF Claimant Information Sheet No. 28320 for the first quarter of 1996 M Application for Tax Credit/Refund of Value Added Tax filed by Petitioner for the first quarter of 1996 N DOF Claimant Information Sheet No. 28319 for the second quarter of 1996 O Application for Tax Credit/Refund of Value Added Tax filed by Petitioner for the second quarter of 1996 P Amended Value-Added Tax Return for the first quarter of 1998 filed by Petitioner on July 20, 1998 Q Amended Monthly VAT Declaration for April 1998 filed by Petitioner on July 20, 1998 R Amended Monthly VAT Declaration for May 1998 filed by Petitioner on July 20, 1998 S Report on the results of procedures performed by SGV & Co. on input tax claims for the first and second quarters of 1996 T-1/l to T-74/3 Schedule of input taxes together with the official receipts and invoices for the period January I to March 31, 1996 issued by Petitioner's suppliers of goods and services U-1/1 to U-126 Schedule of input taxes together with the official receipts and invoices for the period April 1 to June 30, 1996 issued by Petitioner's suppliers of goods and services Respondent, on his part, manifested during the hearing of May 27, 1999, that since there is no report of investigation from the One-Stop-Shop of the Department of Finance, he is submitting the case for decision without presenting any evidence (p. 124 CTA Records). Thus, after a careful evaluation of the evidence submitted by Petitioner, We rule in its favor. Being a 100% export seller duly registered with the Philippine Economic Zone Authority (PEZA) and with the Bureau of Internal Revenue (BIR) as a value-added taxpayer, this Court is convinced that Petitioner is legally entitled to apply for the refund or issuance of a tax credit certificate of its unutilized VAT input payments (Exhibits B and C). Likewise, Petitioner's claim for refund filed with the Department of Finance One-Stop-Shop Inter-Agency Tax Credit and Duty Drawback Center on March 27, 1998 as well as with this Court on March 31, 1998 are both well within the two year period from the dates of the filing of Petitioner's first and second quarterly returns which are April 22, 1996 and July 22, 1996, respectively. Furthermore, to prove that Petitioner carried over its input taxes for the first two quarters of 1996 only until the final quarter of 1997 after which it already opted to file a claim for refund on March 27, 1998. Petitioner presented all its quarterly value-added tax returns up to the first quarter of 1998 and its monthly VAT declaration for April and May of 1998 (Exhibits D to K, P, Q and R). Finally, Petitioner submitted the invoices/official receipts evidencing the input tax payments made during the period covered. However, an examination of the said invoices and receipts showed that not all could qualify as valid invoices and receipts for the refund of input VAT payments. Consequently, the Court was constrained to reduce the amount claimed for the reasons stated hereunder: Should be Subject of Per Claim Per Return the Claim 1st Quarter 1996 (Exhs. L,M,&D) P14,176,601.28 P13,118,542.00 P13,118,542.00 2nd Quarter 1996 (Exhs. N, O & E) 5,161,820.79 5,128,761.94 5,128,761.94 P19,338,422.07 P18,247,303.94 P18,247,303.94 ============== ============= ============ Less: Disallowances per Court's Findings (Annex A) 1.) Purchases supported by invoices/official receipts without TIN-V or TIN-VAT P271,779.70 2.) Purchases supported by stamped TIN-V or TIN-VAT invoices/official receipts 25,339.85 3.) Purchases of VAT-exempt goods/services 12,962.99 4.) Purchases without TIN-V or TIN-VAT invoices/official receipts but supported only by documents such as check vouchers, provisional receipts, acknowledgment 267,000.52 receipts, deposit slips, etc. 5.) Purchases with invoices/official receipts not in the name of Toshiba Info. Equip. (Phils.) 3,112.65 6.) Purchases reported twice 43,765.46 7.) Purchases without supporting documents 81,272.11 8.) Purchase of motor vehicle with engine displacement of 2000 cc or more not allowable as tax credit in accordance with Section 104(a)(1)(E) of the Tax Code 56,363.64 9.) Purchases not related to capital goods 182,128.60 10.) Purchases of capital goods with incorrect computation of input tax 1,115,532.98 2,059,258.50 Amount Refundable P16,188,045.44 ============= WHEREFORE, in view of all the foregoing, the Court finds the instant petition meritorious and in accordance with law. Accordingly, RESPONDENT is hereby ORDERED to REFUND or in the alternative, ISSUE A TAX CREDIT CERTIFICATE to Petitioner in the reduced amount of P16,188,045.44, representing unutilized input value-added tax payments for the first and second quarters of 1996. SO ORDERED. (SGD.) AMANCIO Q. SAGA Associate Judge WE CONCUR: (SGD.) ERNESTO D. ACOSTA Presiding Judge (SGD.) RAMON O. DE VEYRA Associate Judge ANNEX A COURT'S DISALLOWANCES ON CLAIMED INPUT VAT ON PURCHASES OF CAPITAL GOODS AND SERVICES 1st & 2nd QUARTERS OF 1998 1.) Purchases supported by invoices/official receipts without TIN-V or TIN-VAT Input Tax Claimed-1996 Total Exh. Supplier Remarks Date 1st Qtr. 2nd Qtr. Disallowances T-13/1 to T-13/3 Seawind Realty & Devt. Corp. Rental-Office space 4-Mar-96 P15,174.46 P T-47/1 to t-47/3 Seawind Realty & Devt. Corp. Rental-Office space 21-Feb-96 30,348.92 U-22/1 to U-22/2 Seawind Realty & Devt. Corp. Rental-Office space 4-Apr-96 15,174.46 U-23/1 to U-23/2 Manila Bulletin Advertisement 12-Apr-96 10,017.00 U-30/1 to U-30/2 Daniel Tan Condo unit rental 20-Apr-96 60,805.90 U-47/1 Manila Bulletin Advertisement 7-May-96 5,008.50 U-70 T & P Properties, Inc. Lease of Land 28-May-96 60,038.00 U-83/1 to U-83/2 Seawind Realty & Devt. Corp. Rental-office space 4-Jun-96 15,174.46 U-126 T & P Properties, Inc. Lease of Land 29-Jun-96 60,038 00 subtotal P45,523.38 P226,256.32 P271,779.70 2) Purchases supported by stamped TlN-or -TIN-VAT invoices/official receipts pre-printed after July 31, 1991 T-24/1, T-25/2, T-32/2 L.D. Buenaventura Trading Letterhead/envelopes 29-Mar-96 P236.36 P T-54/1 to T-54/3 L.D. Buenaventura Trading Letter envelopes 23-Feb-96 68.18 T-68/1 to T-68/3 Corporate Resources Grp Emp'ee Handbook 22-Jan-96 7,500.00 T-69/1 to T-69/3 L.D. Buenaventura Trading Letterhead/envelopes 27-Jan-96 236.36 U-19/1 to U-19/2 Corp. Resources Grp. Seminar 1Apr-96 1,150.00 U-36 Manila Bulletin Advertisement 26-Apr-96 5,008.50 U-57/1 to U-57/2 L.D. Buenaventura Trading Letterhead/calling cards 20-May-96 577.27 U-96 H. Sycip Entertainment exp. 14-Jun-96 235.00 U-107/1 to U-107/2 Corporate Resources Grp Seminar fee 20-Jun-96 1,350.00 U-108/1 to U-108/2 Corporate Resources Grp. Prof. Services 20-Jun-96 8,818.18 U-123/1 H. Sycip Entertainment exp. 27Jun-96 160.00 subtotal P8,040.90 P17,298.95 25,339.85 3) Purchases of VAT-exempt goods/services T-14/2 Motorists House, Inc. Gasoline expenses 7-Mar-96 P27.27 P T-14/11 Motorists House, Inc. Gasoline expenses 7-Mar-96 31.82 T-14/9 Motorists House, Inc. Gasoline expenses 7-Mar-96 27.27 T-14/8 Motorists House, Inc. Gasoline expenses 7-Mar-96 40.91 T-14/7 Motorists House, Inc. Gasoline expenses 7-Mar-96 36.36 T-14/6 Motorists House, Inc. Gasoline expenses 7-Mar-96 30.00 T-17/5 Motorists House, Inc. Gasoline expenses 22-Mar-96 27.27 T-17/8 Motorists House, Inc. Gasoline expenses 22-Mar-96 27.27 T-29/1 to T-29/4 Motorists House, Inc. Gasoline expenses 29-Mar-96 133.83 T-56/1 to T-56/6 Motorists House, Inc. Gasoline expenses 26-Feb-96 100.36 T-65/1 to T-65/2 Motorists House, Inc. Fuel/TBA expenses 22-Jan-96 1,090.91 T-23/2 to T-23/5 SGV & Co. Tax services 27-Mar-96 9,681.82 U-38 Motorists House, Inc. Gasoline expenses 30-Apr-96 178.00 U-55 Motorists House, Inc. Gasoline expenses 16-May-96 331.55 U-76/1 to U-76/2 Motorists House, Inc. Gasoline expenses 31-May-96 265.10 U-98 Motorists House, Inc. Gasoline expenses 14-Jun-96 441.34 U-119/1 to U-119/2 Motorists House, Inc. Gasoline expenses 26-Jun-96 491.91 subtotal P11,255.09 P1,707.90 12,962.99 4) Purchases without TIN-V or TIN-VAT invoices/official receipts but supported only by documents such as check vouchers, provisional receipts, acknowledgment receipts, deposit slips, etc. T-16/1 to T-16/3 T & P Properties, Inc. Lease of Land 13-Mar-96 P60,038 00 P T21/1 to T21/3 Manforce, Inc. Background Invest. 25-Mar-96 2,350 00 T-32 Tricom Systems (Phils.), Inc 29-Mar-96 51,045.45 T-60/1 to T-60/3 T & P Properties, Inc. Lease of Land 29-Feb-96 60,038 00 U-24/1 to U-24/2 Universal Holidays, Inc. Airfare 15-Apr-96 2,524 80 U-28/1 to U-28/2 Manforce, Inc. Background Invest. 18-Apr-96 4,393 30 U-31/1 T & P Properties, Inc. Lease of Land 25-Apr-96 60,038 00 U-46/1 to U-46/2 Seawind Realty & Devt. Corp. Rental-Office space 7-May-96 15,174.46 U-61/1 to U-61/2 Manforce, Inc. Background Invest. 23-May-96 7,141.97 U-62 Progress Home & Off. Furn Executive table 23-May-96 845.45 U-69 H Sycip Entertainment exp. 28-Mar-96 690.00 U-106/1 to U-106/2 Universal Holidays, Inc. Airfare-employees 17-Jun-96 2,539.27 U-114 517 Flower Co., Inc. Flower arrangement 20 Jun-96 181.82 subtotal P173,471.45 P93,529.07 267,000.52 5.) Purchases with invoices/official receipts not in the name of Toshiba Information Equipment (Phils.), Inc. U-113 PLDT Telephone charges 20-Jun-96 P- P3,112.65 subtotal P- P3,112.65 3,112.65 6) Purchases reported twice U-48/1 Rest. & Banquet Operations Despedida Luncheon 8-May-96 PP510.35 U-50/1 to U-50/2 TCS Manpower Services Janitorial services 11-May-96 395 77 U-51 U-Blx Corporation Tables & chairs 14-May-96 26,573.70 U-52/1 Ace Car Rentals, Inc. Car rental 15-May-96 183.90 U-53/1 Cauder Trading Bond paper 16-May-96 213.64 U-54/1 Tricom Dynamics, Inc. Photocopying exp. 16-May-96 704.34 U-55 Motorists House, Inc. Gasoline expenses 16-Mar-96 331.55 U-56/1 to U-56/2 Micro-Distributing Int'l. Etherlink-5 units 16-May-96 2,727.27 U-49 Trident Electronics Timekeeping System 16-Mar-96 11,293.12 U-57/1 L.D. Buenaventura Trading Letterhead/calling cards 20-May-96 577.27 U-58/1 Anzo Sales Whiteboard 20-Mar-96 254.55 subtotal P- P43,765.46 43,765.46 7) Purchases without supporting documents First Lepanto Taisho 15-Feb-96 P36,939.71 P Pragmatic Devt. & Const. Corp. 16-Apr-96 44,332.40 81,272.11 subtotal P36,939.71 P44,332.40 81,272.11 8) Purchase of motor vehicle with engine displacement of 2000 cc or more not allowable as tax credit in accordance with Section 104(a)(1)(e) of the Tax Code (Section 4.104-1(a)(5) of Rev. Reg. 7-95) U-88 Mantrade Nissan Vanette, 2000 14-Jun-96 P56,363.64 subtotal P56,363.64 56,363.64 9) Purchases not related to capital goods T-14/1 to T-14/5 Motorists House, Inc. Car wax 7-Mar-96 P27.92 P T-15/1 to T-15/4 TCS Manpower Services Janitorial Services 11-Mar-96 290.63 T-17/9 to T-17/11 Motorists House, Inc. Supplies-car maintenance 22-Mar-96 281 69 T 19/1 to T-19/4 TCS Manpower Services Janitorial services 25-Mar-96 29735 T-20/1 to T-20/3 SM Appliance Center Rechargeable lanterns 25-Mar-96 708.36 T-22/1 to T-22/4 Eroann Corporation Business envelopes 26-Mar-96 459.09 T-27/1 to T-27/3 Technical House of Repair Repair-airconditioner 29-Mar-96 243.22 T-28/1 to T-28/3 Savior Security Security services 29-Mar-96 1,747.60 T-34/1 to T-34/2 K Line Air Service Phils. Inc. Airline Fees 5-Feb-96 236.25 T-35/1 to T-35/3 Airfreight 2100, Inc. Custom Duties 7-Feb-96 1,190.00 T-37/1 to T-37/2 Brand Asia Limited Prep.-Const. Ceremony 8-Feb-96 1,531.00 T-38/1 to T-38/3 TCS Manpower Services Janitorial services 8-Feb-96 232.86 T-39/1 to T-39/2 Tricom Dynamics Inc. Maint. fee-Copier 8-Feb-96 912.70 T-40/1 to T-40/5 Anson's Emporium Color TV/VHS 14-Feb-96 3,999.09 T-42/1 to T 42/3 Elarmo Enterprises Whiteboard/corkboard 16-Feb-96 763.64 T-45/1 to T-46/3 Tricom Dynamics, Inc. Photocopying exp. 22-Mar-96 381.82 T-48/1 to T-48/3 Info & Campaign Consult. Inc. Media/PR activities 21-Feb-96 2,500.00 T-49/1 to T-49/2 Phil. Daily Inquirer Advertisement 22-Feb-96 5,832.00 T-50/1 to T-50/2 Manila Bulletin Advertisement 22-Feb-96 5,040 00 T-52/1 to T-52/3 TCS Manpower Services Janitorial services 23-Feb-96 274.94 T-57/1 to T-57/3 Universal Holidays, Inc. Airfare 26-Feb-96 5,654.55 T-58/1 to T-58/3 The Manila Southwoods Entrance fees 26-Feb-96 10,000.00 T-59/1 to T-59/2 Savior Security Security services 27-Feb-96 1,763.64 T-61/1 to T-61/3 Technical House of Repair Repair-air conditioner 29-Feb-96 136.36 T-64/1 to T-64/3 Reliance Supp.Co., Inc. Fire Extinguishers 16-Jan-96 772.73 T-66/1 to T-66/3 Mr. Takeo Nagatomo Home appliances 22-Jan-96 498.45 T-67/1 to T-67/2 Office Bear Corp. Translation fee 22-Jan-96 1,700.00 T-70/1 to T-71/2 Savior Security Security services 31-Jan-96 3,527.28 U-25/1 to U-25/3 RCPI Telegram 15-Apr-96 710.74 U-26/1 to U-26/2 TCS Manpower Services Janitorial Services 15-Apr-96 363.03 U-29/1 to U-29/2 Rest & Banquet Operations Lunch-Job interview 16-Apr-96 752.40 U-32/1 to U-32/2 TCS Manpower Services Janitorial services 25-Apr--96 276.09 U-33/1 to U-33/2 Rest. & Banquet Operations Food-Job interview 26-Apr-96 22.00 U-34/1 to U-34/2 Eroann Corporation Office supplies 26-Apr-96 636.36 U-35/1 Speedway Electronics Office supplies 26-Apr-96 738.73 U-37/1 to U-37/2 Savior Security Security services 30-Apr-96 1,763.64 U-37/3 Pilipino Telephone Corp. Cellphone Charge 30-Apr-96 316.07 U-391 to U-39/2 Universal Holidays Inc. Hotel Accommodation 30-Apr-96 13,475.00 U-40 Pragmatic Dev't. & Const. Corp. Rental-Office space 16-Apr-96 11,083.10 U-41/1 to U-41/2 Pragmatic Dev't. & Const. Corp. Rental-Office space 16-Apr-96 11,083.10 U-42/2 USA Trading Corporation Office supplies 2-May-96 200.00 U-43/1 to U-43/2 Universal Holidays Inc. Airfare-Japan trainees 7-May-96 10,779.50 U-44/1 Microphase Laserprinter 7-Mar-96 313.64 U-48/1 to U-48/2 Rest. & Banquet Despedida Luncheon 8-May-96 510.35 U-50/1 to U-50/2 TCS Manpower Services Janitorial services 11-May-96 395.77 U-52/1 to U-52/2 Ace Car Rental, Inc. Car rental 15-May-96 183.90 U-53/1 to U-53/2 Cauder Trading Bondpaper 16-May-96 213.64 U-54/1 to U-54/2 Tricom Dynamics, Inc. Photocopying exp. 16-May-96 704.34 U-58/1 to U-58/2 Anzo Sales Whiteboard 20-May-96 254.55 U-S9/1 to U-59/3 Rest. & Banquet Operations Despedida Luncheon 21-May-96 806.30 U-60 to U-60/1 TCS Manpower Services Manpower services 21-May-96 336.40 U-63/1 to U-63/3 GlobeTelecom Cellphone Charges 24-May-96 629.72 U-64/1 to U-64/2 RCPI Telegram 24-May-96 404.75 U-65/1 to U-65/2 Cauder Trading Bondpaper/bookpaper 24-May-96 156.82 U-66/1 to U-66/2 Universal Holidays Inc. Airfare 24-May-96 1,315.00 U-67/1 to U-67/2 Universal Holidays Inc. Airfare-Japan trainees 24-May-96 18,410.00 U-68 Ace Car Rentals, Inc. Car rental 27-May-96 183.90 U-71/1 to U-71/2 Savior Security Security services 28-May-96 1,763.64 U-72/1 to U-72/2 Tricom Dynamics, Inc. Toner 28-May-96 595.45 U-73 Alta Printing Services Calling cards 28-May-96 224.55 U-74 Universal Holidays Inc. Bus. Trip-Mr. Nagatomo 31-May-96 3,942.64 U-75 Pilipino Telephone Corp. Cellphone Charges 31-May-96 179.85 U-77/1 to U-77/2 RCPI Telegram 31-May-96 727.06 U-82/1 to U-82/2 CauderTrading Office supplies 4-Jun-96 63.64 U-84/1 to U-84/2 Globe Telecom Cellphone Charges 4-Jun-96 122.33 U-85/1 to U-85/2 Takezawa Tech Transfer Consultation fee 4-Jun-96 2,727.27 U-87 Microphase Enterprises Laserprinter toner 11-Jun-96 327.27 U-90 TCS Manpower Services Manpower services 11-Jun-96 386.72 U-91/1 to U-91/2 Tricom Dynamics, Inc. Photocopying exp. 11-Jun-96 169.80 U-93/1 to U-93/2 Universal Holidays Inc. Airfare-Japan trainees 11-Jun-96 5,270.18 U-94/1 to U-94/2 Cauder Trading Office supplies 14-Jun-96 149.45 U-95 Mayland Gen. Merchandise Office supplies 18-Jun-96 584.90 U-97/1 to U-97/2 Alta Printing Services Calling cards 14-Jun-96 397.27 U-100/1l to U-100/2 Cauder trading Office supplies 14-Jun-96 500.23 U-101/1 CauderTrading Office supplies 14-Jun-96 821.82 U-102/2 Technical House of Repair Repair-air conditioner 17-Jun-96 136.36 U-103 Tricom Dynamics, Inc. Photocopying exp. 17-Jun-96 850.44 U-104/1 to U-104/2 Rest. & Banquet Operations Despedida party-trainees 17-Jun-96 667.80 U-105 Universal Holidays, Inc. Airfare-Japan trainees 17-Jun-96 16,784.18 U-110/1 USA Trading Corporation Calculators 20-Jun-96 872.73 U-112/1 to U-112/2 Cauder Trading Office supplies 20-Jun-96 701.45 U-115/1 to U-115/2 TCS Manpower Services Manpower services 24-Jun-96 307.83 U-116 Tricom Dynamics, Inc. Toner 20-Jun-96 595.45 U-117/1 to U-117/2 Oracle Systems Phils. Inc. Reference Manuals 24-Jun-96 10,346.00 U-118/1 to U-118/2 Universal Holidays, Inc. Airfare 24-Jun-96 1,317.55 U-120 Eroann Corporation Calendars 26-Jun-96 272.73 U-121/1 to U-122/2 Flower Express Flower arrangement 27-Jun-96 227.27 U-123/2, U-124 L..D. Buenaventura Trading Window envelopes/I.D. 27-Jun-96 309.09 U-1251 to U-125/2 Savior Security Security services 27-Jun-96 1,763.64 subtotal P51,003.17 P131,125.43 182,128.60 10.) Purchases of capital goods with incorrect computation of input tax T-74/1 to T-74/3 SNK Philippines, Inc. Bldg const. costs 31-Jan-96 Per Claim P2,665,125.00 Should be 1,564,207.55 Disallowance P1,100,917,45 U-51 U-Bix Corp. Various chairs/tables 14-May-96 Per Claim P26,573.70 Should be 11,958.17 Disallowance P14,615.53 subtotal P1,100,917.45 P14,615.53 1,115,532.98 Total Disallowances P2,059,258.60 ============