EMPIRE AUTOMATION PHILIPPINES INC., v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Special Third Division EMPIRE AUTOMATION CTA CASE NO. 10470 PHILIPPINES, INC., Petitioner, Members: -versus- RINGPIS-LIBAN, Chairperson, and MODESTO-SAN PEDRO, JJ Promulgated: COMMISSIONER OF t1AP n 1 2025 INTERNAL REVENUE, Respondent. X -------------------------------------------------------------------------- -------------------------- ---------------- --- X RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's Motion for Reconsideration [To the Decision dated 16 June 2023}, filed on August 29, 2023, without any comment from respondent. 1 The Motion is a non sequitur. The Court did not deny the Petition for Mandamus for lack of merit. We dismissed it for lack ofjurisdiction due to petitioner' s late filing of the Petition. While the Court broached the topics of discretion and the availability of other remedies, such was done for clarificatory purposes only. Petitioner, as such, does not broach the issue of jurisdiction, leaving Our findings on it unchallenged. Consequently, discussing the actual arguments raised is unnecessary-even if the Court were to agree with all of petitioner's points, We would still the lack requisite jurisdiction to grant the relief sought. ACCORDINGLY, petitioner' s Motion for Reconsideration [To the Decision dated 16 June 2023}, filed on August 29, 2023, is hereby DENIED for lack of merit. The Decision, dated June 16, 2023, is hereby AFFIRMED., See Records Verification, dated Fe bruary 17, 2025, Rollo, unpaginated.

RESOLUTION CTA CASE NO . 10470 Page 2 of2 SO ORDERED. WE CONCUR: f/L.~ -?'- MA. BELEN M. RINGPIS-LffiAN Associate Justice