Sitel philippines Corporation vs CIR

Facts:

The petitioner is a corporation organized under the Philippine law and engaged in business of providing
call center services from Philippines to domestic and offshore businesses. It was registered as a VAT
taxpayer with the BIR and filed quarterly VAT returns therein. On March 30, 2006 Sitel filed a judicial
claim for tax refund with CTA after filing a formal claim with One Stop Shop Inter-Agency Tax Credit and
Duty Drawback Center of the Department of Finance for unutilized input VAT arising from domestic
purchases of goods and services attributed to zero-rated transaction and purchases/importations of
capital goods. The CTA partially grants the tax refund and denying the claim for unutilized input VAT
attributable to its zero-rated sales on the ground that Sitel failed to prove that the recipient of its
services are doing business outside the Philippines. The CTA also reduced the claim for input VAT paid on
capital goods purchase for failure to require with the invoicing requirements. Sitel moved the case to