STEFANINI PHILIPPINES, INC. v. COMMISSIONER OF INTERNAL REVENUE

CTA Fonn No.8 (For DCC) 11111111111111111111111111111111111111111111111111111111111111 111111111111111111 22-000572-0056 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION CTA CASE NO. 11039 STEFANINI PHILIPPINES, INC., Petitioner, -versus - NOTICE OF RESOLUTION COMMISSIONER OF INTERNAL REVENUE, Respondent To: OFFICE OF TH E SOLICITOR GENE RAL 134 Amorsolo St., Legazpi Village Makati City ATTY. FELIX PAUL R. VELASCO III ATTY. SYLVIA R. ALMA JOSE ATTY. AYESHA BANIA B. GUILING-MATANOG ATTY. BRYAN ANTHONY C. DIEGO Bureau of Intenral Revenue Litigation Division, Room 703, BIR National Office Building Sen. Miriam P. Defensor-Santiago Avenue Diliman, Quezon City MENDOZA CALNEA MANGUNDAYAO AND ASSOCIATES U-23 10 Prestige Tower Condominium F. Ortigas Jr. Road, Ortigas Center Pasig City GREETINGS: You are hereby notified by these presents that on January 5, 2026, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, January 5, 2026. ,h. J~na tty. Maria F. Chan-Te Jr1 Executive Clerk of Court III

REPUBLIC OF THE PHILIPPINES � COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION STEFANINI PHILIPPINES, CTA CASE NO. 11039 INC. , Petitioner, Members: -versu s- BACORRO-VILLENA, Acting Chairperson, and CUI-DAVID, JJ. . COMMISSIONER OF Promulgated : INTERNAL REVENUE, Respondent. r �- . JAN 0 5 2026 � ~-- � �""---- 2 ~ ~ l> ){- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -){ RESOLUTION CUI-DAVID, J.: Th is resolves respondent's Motion for Partial Reconsideration (Re: Decision promulgated on 27 June 2025)1 (Motion), filed on July 9 , 2025, with petitioner's Comment/ Opposition [to Respondent's Motion for Partial Reconsideration (Re: Decision promulgated on 27 June 2025)], file d on September 17, 2 0 2 5. Respondent seeks partial reconsideration of the Court's Decision2 promulgated on June 27 , 2025 (assailed Decision), the dispositive portion of which reads: WHEREFORE, in ligh t of the foregoing considerations, the present Petitionfor Re view is PARTIALLY GRANTED. Accordingly, responden t is ORDERED TO REFUND.or ISSUE A TAX CREDIT CERTIFICATE in favor of petitioner in th e amount of P3 21, 188.87, represen tin g its excess and unutilized in put VAT attributable to its zero-rated sales for Docket, pp. 962- 968. !d. at 924-96 1.

RESOLUTION CTA Case No. 11039 Stefanini Philippines, Inc. v. Commissioner of Internal Revenue x------------------------------------------------------------------------------------x the 2nd quarter of CY 2020, which is in addition to the 1"380, 165.46 previously granted by respondent in petitioner's administrative claim for refund, as stated in the VAT Refund Notice dated September 5, 2022.3 SO ORDERED. Respondent anchors his Motion on the sole ground that the Court erred in ruling that petitioner is partially entitled to the refund sought. He argues that petitioner bears the burden of proving the factual basis of its claim for tax credit or refund, which petitioner allegedly failed to discharge because the documents it submitted did not comply with the requirements of law. In opposing the Motion, petitioner counters that respondent merely rehashes the same arguments raised in his Answer dated March 6, 2023, which he adopted as his Memorandum through his Manifestation 4 filed on May 23, 2024, which had all been considered and passed upon in the assailed Decision. Petitioner further asserts that it was able to establish its entitlement to the amount granted in the assailed Decision. Respondent's Motion must fail. After a judicious examination of the records and careful evaluation of the arguments raised in the Motion, the Court finds no cogent reason to disturb its ruling in the assailed Decision. Respondent presents no new matters, substantial issues, or persuasive arguments that would warrant reconsideration or modification. His arguments have already been thoroughly discussed and passed upon by the Court in pages 11 to 37 of the assailed Decision. Reiterating the same discussion would serve no useful purpose and would only waste judicial resources. WHEREFORE, premises considered, respondent's Motion for Partial Reconsideration (Re: Decision promulgated on 27 .June 2025) is hereby DENIED for lack of merit. !d. at 960. !d. at 877.

RESOLUTION CTA Case No. 11039 Stefanini Philippines, Inc. v. Commissioner of Internal Revenue x------------------------------------------------------------------------------------x SO ORDERED. /bwn~M� LANEE S. CUI~dAVID Associate Justice !CONCUR: ' JEAN MARl