PROMESSO BUSINESS SOLUTIONS CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Special Second Division PROMESSO BUSINESS CTA CASE N0.10529 SOLUTIONS CORPORATION, Petitioner, Members: -versus- RINGPIS-LIBAN, PJ, Chairperson, MODESTO-SAN PEDRO, and FERRER-FLORES, JJ Promulgated: COMMISSIONER OF INTERNAL REVENUE, Respondent. X ---------------------------------------------------------------------------------------------------------------- RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Reconsideration (of Decision dated February 5, 2026), filed on March 6, 2026, with petitioner's Comment/Opposition thereto, filed on April 17, 2026, assailing this Court's Decision, dated February 5, 2026. The motion lacks merit. Respondent essentially denies having violated petitioner's due process rights by forwarding a specific definition of due process. The definition offered by respondent, however, contradicts Commissioner of Internal Revenue v. Fitness By Design, Inc. 1 and Commissioner ofInternal Revenue v. Avon Manufacturing, Inc.,2 which served as the jurisprudential bases for Our ruling. Further, respondent does not show why such jurisprudence should be disregarded here, tellingly avoiding any mention of said rulings. The motion consequently fails to even identifY why We declared the assessment void, much less substantially challenge such ruling. r We consequently see no reason to reverse the assailed Decision. G.R. No. 215957, November 9, 2016. G.R. Nos. 201398-99, October 3, 2018.

RESOLUTION CTA CASE NO. 10529 Page 2of2 FOR THESE REASONS, respondent's Motion for Reconsideration (of Decision dated February 5, 2026), filed on March 6, 2026, is hereby DENIED for lack of merit. SO ORDERED. WE CONCUR: ~.~J- MA. BELEN M. RINGPIS-LIBAN Presiding Justice ~f"-r~& CORA�ON G. F'ERRER-FL RES Associate Justice