COMMISSIONER OF INTERNAL REVENUE v. ROYAL CARIBBEAN CRUISES LTD., doing business under the name RCL REGIONAL OPERATING HEADQUARTERS

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTA EB NO. 2886 REVENUE, (CTA Case No. 10256) Petitioner, Present: RINGPIS-LIBAN, PJ, -versus- BACORRO-VILLENA, MODESTO-SAN PEDRO, REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, and ROYAL CARIBBEAN CRUISES ANGELES, JJ LTD., doing business under the name RCL REGIONAL OPERATING Promulgated: HEADQUARTERS, Respondent. JUN 24 ~ x ------------------------------------------------------------------~~~!~-~~~x~ � RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's Motion for Reconsideration (of the Decision dated 02 December 2025), filed via registered mail on December 18, 2025, assailing this Court' s December 2, 2025 Decision, without any comment from respondent. 1 The Motion lacks merit. Respondent essentially raises three arguments against Our ruling: ( 1) that respondent did not make an erroneous payment that entitles it to a refund; (2) that respondent failed to exhaust administrative remedies; and (3) that respondent failed to substantiate its claim. The first two ofthese, however, are rehashes of petitioner's arguments from its Petition for Review. While lightly r Records Verification, February 27, 2026, Rollo, unpaginated.

R[SQI.lTIO" CTA EB No_ 2886 (CTA Case :"Jo. 10256) Page 2 of3 edited, with some parts removed, said arguments mainly consist of paragraphs copied near-verbatim from the Petition. These have consequently already been addressed and refuted in the Assailed Decision. Thus, there is no need to repeat Our discussions by covering these again. 2 As for petitioner's contention that respondent failed to substantiate its refund claim, the argument is made via general, platitudinous statements about substantiating refund claims. These are not, however, actually applied to the case at bar or to the specific findings of the CoUJi in Division. Being devoid of substance, they pose no actual challenge to Our ruling. FOR THESE REASONS, petitioner's Motion for Reconsideration (of the Decision dated 02 December 2025), filed via registered mail on December 18, 2025, is hereby DENIED for lack of merit. The Decision, dated December 2, 2025, is AFFIRMED. SO ORDERED. WE CONCUR: MA. BELEN M. RINGPIS-LIBAN Presiding Justice ~~F~-f=ot~ MARIAN IVif F. REY'ES-FA.fARDO Associate Justice See Roque r. Commission on Election. G.R. No. 188456 (Resolution). february I0, 20 I0; sec also Shangri-La /nlernationa/ Hotel J1anagemenl. Ltd. r. Developers Group qlCompanies. Inc., G.R. No. 159938 (Resolution), Janual)' 22. 2007: see also Ortigas and Company Limited Parmership v. Velasco, G.R. Nos. 109645 & 112564 (Resolution). March 4. 1996.

R[SOUTIO' CTA EB No_ 2886 {CTA Cas~ No_ 102)6 l Page 3 of3 Associate Justice j/JL HENRYS. ANGELES Associate Justice