WATSONS PERSONAL CARE STORES (PHILIPPINES), INC. v. COMMISSIONER OF INTERNAL REVENUE

'! REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL SECOND DIVISION WATSONS PERSONAL CARE CTA CASE NO. 10504 STORES (PHILIPPINES), INC., Petitioner, Members: -versus- RINGPIS-LIBAN, Chairperson MODESTO-SAN PEDRO, and FERRER-FLORES, JJ COMMISSIONER OF Promulgated: INTERNAL REVENUE, 1.''/?- Jl11 X - - - - - - - - - - - - - - - - -~~s~~~~~n:------------------------ -~j, ('h, RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Partial Reconsideration (Re: Decision promulgated on 16 February 2026), filed on March 9, 2026, with petitioner's Comment, filed on April 15, 2026, against this Court's Decision dated February 16, 2026 ("Assailed Decision") partially granting petitioner's claim for refund of its excess and unutilized creditable withholding taxes ("CWT") for taxable year ("TY") 2018. Respondent insists that the Court erred in ruling that petitioner is entitled to the refund claimed as it failed to: (1) establish the direct linkage between the CWT and the income as reflected in the Annual Income Tax Return; (2) comply with Revenue Memorandum Order No. 53-98 and Revenue Regulations No. 2-2006; and (3) prove the actual remittance of the taxes withheld. However, as pointed out by petitioner in its Comment, respondent's arguments are a mere rehash of those raised in his Answer- arguments which were already considered by the Court when it rendered the Assailed Decision and squarely discussed therein. Without any new substantial and persuasive

., 1 RESOU'TIO~ CTA Case No. I0504 Page 2 of2 argument from respondent worthy of the Court's consideration, We shall no longer belabor discussing these matters again. Indeed, while a motion for reconsideration, by its nature, may tend to dwell on issues already resolved in the decision or resolution sought to be reconsidered, a circumstance which should not be an obstacle for a reconsideration, [respondent] must still raise matters substantially plausible or compellingly persuasive to warrant a reversal of the Court's previous ruling. 1 Further, the grounds relied on being mere reiterations of the issues already passed upon by the Court, there is no need to "cut and paste" pertinent portions of the Decision or re-write the ponencia in accordance with the outline of the instant motion.2 FOR THESE REASONS, respondent's Motion for Partial Reconsideration (Re: Decision promulgated on 16 February 2026) is DENIED for lack of merit. SO ORDERED. ~~~ WE CONCUR: ~.~J-- MA. BELEN M. RINGPIS-LIBAN Presiding Justice ~A/. CORA~G.F Associate Justice Department ofEnergy v. Commissioner ofInternal Revenue, G.R. No. 2609 I2 (Resolution), August 30, 2023. Social Justice Society Officers v. Lim, G.R. Nos. I87836 & I879 I6 (Resolution), March I0, 20 I5.