Royal Bank of Canada v. Tax Court of Puerto Rico

Mr. Justice De Jesús

delivered tbe opinion of the court.

This proceeding was instituted in order to review a decision of the Tax Court of Puerto Rico dismissing a complaint filed by The Royal Bank of Canada against a ruling of the Treasurer of Puerto Rico, 'rendered on October 20, 1941, denying a certain petition for refund presented by that bank. The facts of this case may be summarized thus:

On February 14, 1941, the bank filed its income tax return covering the period from December 1, 1939, to November 30, 1940, and on the same day it paid the tax on its net income at the rate of 14.375 per…