GMA WORLDWIDE (PHILS.), INC. v. COMMISSIONER OF INTERNAL REVENUE

CTA Form No. 8 (For DCC) 11111111111111111111111111111111 111111111111111 1111111111 1111111111 1111111111111 23-000213-0047 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION CTA CASE NO. 11158 NOTICE OF RESOLUTION GMA WORLDWIDE (PHILS.), INC., Petitioner, - versus- COMMISSIONER OF INTERNAL REVENUE, Respondent. To: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo Street, Legazpi Village Makati City ATTY. DAYNE B. MEDINA ATTY. SHEEHERAZADEE A. LABOR-MORAN ATTY. XINIA CARMELA B. CRUZ-LAVER ATTY. PAULYN ANN A. UMIPIG-LABUCAY ATTY. ROHANAH D. RADIAMODA Bureau oflntemal Revenue Revenue Region 7A- Legal Division Room 516, RoofDeck, Fisher Mall Fernando Poe Jr. Avenue comer Quezon Avenue, Quezon City SALVADOR LLANILLO & MIJARES Units 1706-1711, 17th Floor, Tower One & Exchange Plaza Ayala Triangle, Ayala Avenue GREETINGS: You are hereby notified by these presents that on February 20, 2026, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, February 25, 2026. ~tty. Maria J~a F. Chan-Te \ 1-l Executive Clerk of Court III

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION GMA WORLDWIDE CTA CASE NO. 11158 (PHILS.), INC., Members: Petitioner, -versus- BACORRO-VILLENA, Acting Chairperson, and CUI-DAVID, JJ. COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. FEB 20 2026 ; j .' IJOPM ){- - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - -){ RESOLUTION CUI-DAVID, J.: This resolves respondent's Motion for Reconsideration, 1 filed on August 22, 2025, with petitioner's Comment (Re: Respondent's Motion for Reconsideration)} filed on November 3, 2025. Respondent seeks reconsideration of the Court's Decision2 promulgated on August 1, 2025 (assailed Decision), the dispositive portion of which reads: WHEREFORE, the Petition for Review filed by GMA Worldwide (Phils.), Inc. is GRANTED. Accordingly, respondent's Notice of Denial dated April 3 , 2023, is hereby ANNULLED, REVERSED, and SET ASIDE. The deficiency Value-Added Tax assessment contained in the Formal Letter of Demand/ Final Assessment Notices, and the subject of th e instant appeal, demanding the payment of the amount of P573,425. 13, plus all increments incident to the delinquency, is CANCELLED and SET ASIDE. Docket, pp. 544-549. 2 ld. at 523-543.

RESOLUTION CTA Case No. 111 58 GMA Worldwide (Phils.), Inc. v. Commissioner of Internal Revenue x----------------------------- ----- -------- -- --- -- ---- ----- ----- -- ------ -------------x SO ORDERED. Respondent anchors the Motion on the sole ground that the Court allegedly erred in ruling that the deficiency value- added tax (VAT) assessment is void for lack of factual basis and for violation of petitioner's right to due process. According to respondent, petitioner submitted documents for taxable year 2011. The said documents were verified, resulting in a deficiency VAT assessment. Thus, respondent maintains that, contrary to the Court's findings, the assessment in question is not a naked assessment. Respondent also disagrees with the Court's finding that petitioner's right to due process was violated. Respondent avers that the Preliminary Assessment Notice (PAN) and Final Assessment Notice (FAN) were received by petitioner on March 12, 2015, and March 30, 2015, respectively. Allegedly, petitioner received the FAN eighteen (18) days after receipt of the PAN. For respondent, the mere fact that the FAN carried an earlier issuance date does not automatically invalidate the assessment, since petitioner allegedly had the full fifteen (15) days from receipt of the PAN to dispute the assessment. In its Comment, petitioner submits that respondent failed to raise any new or compelling argument in his Motion that has not already been deliberated upon by the Court in the assailed Decision. Hence , it prays for the Court to deny respondent's Motion for Reconsideration for lack of merit. Respondent's Motion is unavailing. After a careful examination of the records and a meticulous evaluation of the arguments raised in the Motion, the Court finds no cogent reason to disturb its ruling in the assailed Decision dated August 1, 2025 . The matters raised therein have already been fully discussed and resolved by the Court in pages 8 to 20 of the assailed Decision. A restatement thereof would serve no useful purpose. In Shangri-La International Hotel Management, Ltd. v. Developers Group of Companies, Inc. , 3 the Supreme Court emphasized that it is incumbent upon the movant to convince G.R. No. 159938, January 22, 2007 [Per J. Garcia, First Division], citing Ortigas and Co. Ltd. Partnership v. Judge Velasco, G.R. No. I09645, March 4, 1996 [Per C.J. Narvasa, Third Division).

RESOLUTION CTA Case No. 11158 GMA Worldwide (Phils.) , Inc. v. Commissioner of Internal Revenue X------------------------------------------------------------------------------------X the Court that certain findings or conclusions are contrary to law, as follows: The bulk of the aforementioned grounds is a mere rehash of movant's previous arguments. While DGCI is correct in stating that a motion for reconsideration, by its very nature, may tend to dwell on issues already resolved in the decision sought to be reconsidered and that this should not be an obstacle for a reconsideration, the hard reality is that movant has failed to raise matters substantially plausible or compellingly persuasive to warrant the desired course of action. Considering that the grounds presently raised have been sufficiently considered, if not squarely addressed, in the subject Decision, it behooves movant to convince the Court that certain findings or conclusions in the Decision are contrary to law. As it is, however, the instant motion does not raise any new or substantial legitimate ground or reason to justify the reconsideration sought. As no new matters or issues have been presented that would warrant reconsideration, much less modification, of the assailed Decision dated August 1, 2025, the Court is constrained to deny the Motion for lack of merit. WHEREFORE, premises considered, respondent's Motion for Reconsideration is hereby DENIED for lack of merit. SO ORDERED. LA~1rf.viD Associate Justice !CONCUR: JEANMA A. BACORRO-VILLENA