ASURION HONG KONG LIMITED - ROHQ v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS Quezon City Second Division ASURION HONG KONG LIMITED CTA CASE NO. 10413 - ROHQ, Members: Petitioner, RINGPIS-LIBAN, Chairperson -versus- MODESTO-SAN PEDRO, and FERRER-FLORES, Jl. COMMISSIONER OF INTERNAL Promulgated: SEP 10 2024 REVENUE, Respondent. x---------------------------------------------------------------------------------------~------x DECISION RINGPIS-LIBAN,J: The Case The Petition for Review prays that the Court render judgment ordering respondent to refund petitioner in the amount of Php21,616,914.71 , representing petitioner's excess and unutilized input value-added tax ("VAT") attributable to its zero-rated sales of services for the four (4) quarters of the calendar year ("CY") 2018. 1 The Facts Petitioner Asurion Limited Hong Kong Limited- ROHQ is the Philippine Branch of a multinational company organized and existing under the laws of Hong Kong. 2 It is licensed by the Securities and Exchange Commission ("SEC") to transact business in the Philippines as a regional operating headquarters tJ Docket, Pre-Trial Order dated May 31, 2022, Statement of the Case, p. 495. 2 !d., Exhibits "P-1" and "P-1-a", pp. 530 to 586.

DECISION CTA CASE NO. 10413 ("ROHQ") under SEC Registration No. FS201413422 dated July 17, 2014.3 It holds office at the 17/F ACCRALAW Tower, 30th St. cor 2nd Avenue, Crescent Park West, Bonifacio Global City, Taguig City.4 It is also registered with the Bureau of Internal Revenue ("BIR"), as a VAT Taxpayer under Taxpayer Identification No. ("TIN") 008-817-591-000. 5 Respondent is the duly appointed Commissioner of Internal Revenue, vested under the appropriate laws with the authority to carry out the functions , duties, and responsibilities of his Office, including, inter alia, the duty to act upon and approve claims for refund or tax credit pursuant to the provisions of the National Internal Revenue Code ("NIRC") of 1997, as amended, and other tax laws, rules, and regulations.6 His office address is at the BIR National Office Building, BIR Road, Dillman, Quezon City.7 On June 30, 2020, petitioner flied with the BIR Revenue District Office No. 44 an administrative claim for the refund of its alleged excess and unutilized input VAT for the four (4) quarters of CY 2018 in the total amount of Php21 ,616,914.71. 8 Petitioner then received the letter dated October 05, 2020 from Regional Director Glen A. Geraldino, denying its administrative claim for VAT refund.9 The present Petition ofReviewwas ftled on December 03, 2020.10 In his Answer posted on March 11, 2021,11 respondent interposed the following special and affirmative defenses, to wit: (1) petitioner failed to establish that it is entitled to the refund of its excess and unutilized input VAT attributable to its zero-rated sales of service during the taxable year 2018; (2) taxes paid and collected are presumed to have been made in accordance with the laws and regulations, hence, not refundable; (3) petitioner's claim for refund was not fully substantiated by proper documents; and (4) only photocopied invoices and official receipts were submitted by petitioner as documentary support for its r claim for refund. 3 Id., Exhibit "P-2", pp. 587 to 607. 4 Id., Joint Stipulation of Facts and Issues (JSFI), Stipulation of Facts, Par. 2, p. 322. 5 Id., JSFI, Stipulation of Facts, p. 322; Exhibit "P-3", p. 608. 6 Id., JSFI, Stipulation of Facts, p. 323. 7 Id. 8 Id., JSFI, Stipulation of Facts, JSFI, p. 323; Exhibits "P-11", "P-12", and "P-13", pp. 708 to 714. 9 Id., JSFI, Stipulation of Facts, p. 323; Exhibit "P-15", p. 716. 10 Id., pp. 7 to 27. 11 Id., pp. 243 to 248.

DECISION CTA CASE NO. 10413 On May 17, 2021, respondent transmitted the BIR Records for this case.12 The Pre-Trial Conference was initially set on August 26, 2021,13 but was subsequently reset to, and held on, February 16, 2022. 14 During the said Conference, respondent's counsel manifested that she will not present any witness. Prior thereto, Petitioner's Pre-Trial Briefwas flied on November 23, 2021,15 while Respondent's Pre-Trial Briefwas posted on December 16, 2021.16 On March 17, 2022, the parties flied their Joint Stipulation of Facts and Issues,17 which was approved and adopted by the Court in its Resolution dated March 22, 2022,18 thereby deeming the termination of the Pre-Trial. The Pre- Trial Order dated May 31, 2022 was then issued.19 Trial then ensued. Petitioner presented its documentary and testimonial evidence. It offered the testimonies of the following individuals, namely: (1) Mr. Santiago De Guzman II,20 petitioner's Finance Manager; and (2) Mr. Jay Ballesteros,21 the Court-commissioned independent certified public accountant ("ICPA").22 The Report of the ICPA was submitted on April18, 2022. 23 On June 29, 2022, petitioner flied its Formal Offer of Evidence/4 to which respondent flied his Comment/ Opposition (Io Petitioner's Formal Offer ofEvidence dated June 29, 2022) on August 01, 2022.25 In the Resolution dated November 18, 2022,26 the Court admitted all of petitioner's offered exhibits, except Exhibit "P- f' 12 !d., Transmittal of BIR Records dated March 25, 2021, pp. 239 to 241. 13 Id., Notice of Pre-Trial Conference dated May 26, 2021, pp. 250 to 251. 14 !d., Notice of Resetting dated October 11, 2021, p. 266; Minutes of the hearing held on, and Order dated, February 16, 2022, pp. 312 to 315. 15 !d., pp. 267 to 288. 16 !d., pp. 303 to 306. 17 !d., pp. 322 to 332. 18 !d., p. 334. 19 Id., pp. 495 to 501. 20 Id., Exhibit "P-17", pp. 214 to 229; Minutes of the hearing held on, and Order dated, May 31, 2022, pp. 489 and 492 to 493, respectively. 21 Id., Exhibit "P-18", pp. 466 to 484; Minutes of the hearing held on, and Order dated, May 31, 2022, pp. 489 and 492 to 493, respectively. 22 !d., Oath of Commission dated February 21, 2022, p. 320; Minutes of the hearing held on, and Order dated, February 16, 2022, pp. 312 to 315. 23 Jd., Exhibit "P-19", pp . 343 to 457. 24 Id., pp. 503 to 529. 25 Id., pp. 728 to 740. 26 !d., pp. 746 to 748.

DECISION CTA CASE NO. 10413 1-a", for failure to identify, and Exhibits "P-22-a" to "P-22-d" and "P-22-e" to "P-22-h", for failure to correspond with the document actually marked. Thereafter, on December 07, 2022, petitioner filed an Omnibus Motion (i) Motion for Reconsideration (Re: Resolution dated November 18, 2022) (ii) Motion for Leave ofCourt to Ruall Witness. 27 On December 23, 2022, petitioner filed a Motion to Defer Filing ofPetitioner's Memorandum, 28 which the Court granted in the Resolution dated February 06, 2023,29 in the interest of justice. Prior thereto, respondent's Memorandum and Comment/ Opposition (To Petitioner's Omnibus Motion for Reconsideration and Motion for Leave of Court to Recall Witness) were posted on]anuary 4, 202330 and January 16, 2023,31 respectively. In the Resolution dated March 17, 2023/2 the Court granted petitioner's Motion for Leave of Court to Recall Witness, thereby setting the case for the recall of petitioner's witness, Mr. Sonny De Guzman II, on May 24, 2023; and directing petitioner to ftle its Supplemental Formal Offer ofEvidence, within five (5) days from the said hearing. During the hearing held on May 24, 2023, petitioner's counsel recalled to the witness stand petitioner's witness, Mr. De Guzman,33 who testified on direct examination by way of his Supplemental Sworn Statement dated May 18, 2023, and his testimony was considered terminated. On May 26, 2023, petitioner flied its Supplemental Formal Offer ofEvidence.34 Respondent failed to file his comment thereon. 35 In the Resolution dated August 2, 2023, 36 the Court granted petitioner's Supplemental Formal Offer of Evidence, admitting petitioner's offered exhibits. In the same Resolution, the Court granted petitioner's Motion for Reconsideration (Re: Resolution dated November 18, 2022), thereby admitting Exhibits "P-22-a" to "P-22-d" and "P-22-e" to "P-22- h". r 27 Id./ pp. 750 to 765. 28 Id./ pp. 768 to 770. 29 Id./ p. 795. 30 !d./ pp. 771 to 784. 31 Id./ pp. 787 to 792. 32 Id./ pp. 797 to 799. 33 Jd./ Exhibit "P-47", pp. 803 to 806; Minutes of the hearing held on, and Order dated, May 24, 2023, pp. 808 to 810. 34 !d./ pp. 815 to 818. 35 !d./ Records Verification dated June 26, 2023 issued by the Judicial Records Division of this Court, p. 820. 36 Id./ pp. 822 to 826.

DECISION CTA CASE NO. 10413 In the meantime, the present case was transferred from the Third Division of this Court to its Second Division, per the Resolution dated June 01, 2023.37 Petitioner's Memorandum was submitted on September 07, 2023.38 This case was considered submitted for decision on September 14,2023.39 Hence, this Decision. The Issue The parties stipulated the following issue for this Court's resolution, to wit: "Whether or not Petitioner is entitled to the refund of the amount of Php21,616,914.71 representing its alleged excess and unutilized input VAT attributable to its zero-rated sales of services for the four (4) quarters of calendar year 2018."40 PetitionerJs arguments: Petitioner argues that it is a VAT-registered entity; that its sales of services to persons who are engaged in business conducted outside the Philippines are zero-rated sales; that it paid or incurred input VAT during the period of claim which are properly substantiated in accordance with law and regulations; that the input VAT paid or incurred by petitioner are attributable to zero-rated sales; that the input VAT have not been applied against output taxes during and in the succeeding periods; and that petitioner's claim for refund was flied within the mandatory period provided under the law. RespondentJs counter-arguments: Respondent contends that petitioner must comply with all the requisites provided by law in order to be entitled to a refund; that petitioner failed to substantiate its claim for tax refund at the administrative level resulting in the denial of its claim for VAT refund, hence, its judicial claim should also be dismissed; that petitioner's big-ticket purchases from Tesoro Alegre, Inc. and 37 Id., Notice, p. 819. f 38 Id., pp. 827 to 863. 39 Id., Minute Resolution dated September 14, 2023, p. 864. 4o Jd., Stipulated Issue, JSFI, p. 323.

DECISION CTA CASE NO. 10413 Asalus Corporation were not properly substantiated; and that petitioner's exhibits should not be given any probative value for being hearsay evidence. DiscussionI Ruling The present Petition for Review is partly meritorious. Requisites for the grant ofthe refund or issuance of tax credit certificate under the Jaw. Refunds of input VAT are covered under Section 112 of the NIRC of 1997, as last amended by Republic Act ("RA") No. 10963,41 which provides, in part, viz: "SEC. 112. Refunds or Tax Credits ofInput Tax.- (A) Zero-Rated or Effective!J Zero-Rated Sales. - Any VAT- registered person, whose sales are zero-rated or effectively zero- rated may, within two (2) years after the close of the taxable quarter when the sales were made, apply for the issuance of a tax credit certificate or refund of creditable input tax due or paid attributable to such sales, except transitional input tax, to the extent that such input tax has not been applied against output tax: Provided, however, That in the case of zero-rated sales under Section 106(A)(2)(a)(1), (2) and (b) and Section 108(B)(1) and (2), the acceptable foreign currency exchange proceeds thereof had been duly accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP): Provided, further, That where the taxpayer is engaged in zero-rated or effectively zero-rated sale and also in taxable or exempt sale of goods of properties or services, and the amount of creditable input tax due or paid cannot be directly and entirely attributed to any one of the transactions, it shall be allocated proportionately on the basis of the volume of sales: Provided,final!J, That for a person making sales that are zero-rated under Section f/ 41 AN ACT AMENDING SECTIONS 5, 6, 24, 25, 27, 31, 32, 33, 34, 51, 52, 56, 57, 58, 74, 79, 84, 86, 9~ 91, 97, 99, 100, 101, 106, 107, 10~ 109, 110, 112, 114, 116, 127, 128, 129, 145, 148, 149, 151, 155, 171, 174, 175, 177, 178, 179, 180, 181, 182, 183, 186, 188, 189, 190, 191, 192, 193, 194, 195, 196, 197, 232, 236, 237, 249, 254, 264, 269, AND 288; CREATING NEW SECTIONS 51-A, 148-A, 150-A, 150-B, 237-A, 264-A, 264-B, AND 265-A; AND REPEALING SECTIONS 35, 62, AND 89; ALL UNDER REPUBLIC ACT 8424, OTHERWISE KNOWN AS THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED, AND FOR OTHER PURPOSES.

DECISION CTA CASE NO. 10413 108(B)(6), the input taxes shall be allocated ratably between his zero-rated and non-zero-rated sales. XXX XXX XXX (C) Period within whit"h Refund ofInput Taxes shall be Made.- In proper cases, the Commissioner shall grant a refund for creditable input taxes within ninety (90) days from the date of submission of the official receipts or invoices and other documents in support of the application filed in accordance with Subsections (A) and (B) hereof: Provided, That should the Commissioner find that the grant of refund is not proper, the Commissioner must state in writing the legal and factual basis for the denial. In case of full or partial denial of the claim for tax refund, the taxpayer affected may, within thirty (30) days from the receipt of the decision denying the claim, appeal the decision with the Court of Tax Appeals: Provided, however, That failure on the part of any official, agent, or employee of the BIR to act on the application within the ninety (90)-day period shall be punishable under Section 269 of this Code." Under the above cited section, there are certain requisites which the taxpayer-applicant must comply to successfully obtain a credit/refund of input VAT, as follows: As to the timeliness of the filing of the administrative and judicial claims: 1. the refund claim is ftled with the BIR within two (2) years after the close of the taxable quarter when the sales were made;42 2. in case of full or partial denial of the refund claim rendered within a period of ninety (90) days from the date of submission of the official receipts or invoices and other documents in support of the application, the judicial claim shall be ftled with this Court within thirty (30) days from receipt of the decision; B!r With reference to the taxpayer's registration with the 42 Intel Technology Philippines/ Inc. v. Commissioner ofInternal Revenue, G.R. No. 155732, April 27, 2007; San Roque Power Corporation v. Commissioner of Internal Revenue, G.R. No. 180345, November 25, 2009; and AT&T Communications Services Philippines/ Inc. . Commissioner ofInternal Revenue, G.R. No. 182364, August 03, 2010.

DECISION CTA CASE NO. 10413 3. the taxpayer is a VAT-registered person;43 In relation to the taxpayer's output VAT: 4. the taxpayer is engaged in zero-rated or effectively zero-rated sales .44 5. for z'ero-rated sales under Section 106(A)(2)(1) and (2); 106(B); and 1OS(B) (1) and (2)', the acceptable foreign currency exchange proceeds have been duly accounted for in accordance with the Bangko Sentral ng Pilipinas ("BSP") rules and regulations;45 As regards the taxpayer's input VAT being refunded: 6. the input taxes are not transitional input taxes;46 7. the input taxes are due or paid;47 8. the input taxes claimed are attributable to zero-rated or effectively zero-rated sales. However, where there are both zero-rated or effectively zero-rated sales and taxable or exempt sales, and the input taxes cannot be directly and entirely attributable to any of these sales, the input taxes shall be proportionately allocated on the basis of sales volume;48 and 9. the input taxes have not been applied against output taxes during and in the succeeding quarters.49 Additionally, in claims for VAT refund/credit, applicants must satisfy the substantiation and invoicing requirements under the NIRC and other implementing rules and regulations .5� Thus, petitioner's compliance with all the VAT invoicing requirements is required to be able to file a claim for input taxes attributable to zero-rated sales.51 The invoicing and substantiation requirements r 43 !d. 44 !d. 45 !d. 46 !d. 47 !d. 48 Intel Technology Philippines, Inc. v. Commissioner ofInternal Revenue, G.R. No. 155732, April 27, 2007; and San Roque Power Corporation vs. Commissioner of Internal Revenue, G.R. No. 180345, November 25, 2009. 49 Intel Technology Philippines, Inc. v. Commissioner ofInternal Revenue, G.R. No. 155732, April 27, 2007; San Roque Power Corporation v. Commissioner of Internal Revenue, G.R. No. 180345, November 25, 2009; and AT&T Communications Services Philippines, Inc. . Commissioner ofInternal Revenue, G.R. No . 182364, August 03, 2010. 50 Team Energy Corporation v. Commissioner ofInternal Revenue, et. a/., G.R. Nos. 197663 and 197770, March 14, 2018. 51 JRA Philippines, Inc. v. Commissioner ofInternal Revenue, G.R. No. 171307, August 28, 2013 .

DECISION CTA CASE NO. 10413 should be followed because it is the only way to determine the veracity of the taxpayer's claims. 52 Moreover, compliance with all the VAT invoicing requirements provided by tax laws and regulations is mandatory.53 Strict compliance with substantiation and invoicing requirements is necessary considering VAT's nature and VAT system's tax credit method, where tax payments are based on output and input taxes and where the seller's output tax becomes the buyer's input tax that is available as tax credit or refund in the same transaction. It ensures the proper collection of taxes at all stages of distribution, facilitates computation of tax credits, and provides accurate audit trail or evidence for BIR monitoring purposes.54 Furthermore, in cases filed before this Court, which are litigated de novo, party-litigants must prove every minute aspect of their case.55 Thus, it behooves petitioner to show compliance with each of the foregoing requisites and invoicing requirements. As a corollary, the absence of a'!Y of the said requisites is already a valid ground to deny the refund claim. Petitioner's administrative claim was timely filed. The first requisite pertains to the filing of a claim for tax refund or tax credit of input VAT before the BIR, within two (2) years from the close of the taxable quarter when the zero-rated or effectively zero-rated sales were made. The present claim covers the period from January 01,2018 to December 31, 2018. The following table indicates the last day for the filing of an administrative claim for the concerned quarter, to wit: r' 52 Nippon Express {Philippines) Corporation v. Commissioner of Internal Revenue, G.R. No. 191495, July 23, 2018. 53 Eastern Telecommunications Philippines, Inc. v. Commissioner of Internal Revenue, G.R. No. 183531, March 25, 2015. 54 Team Energy Corporation v. Commissioner ofInternal Revenue, et. a/., G.R. Nos. 197663 and 197770, March 14, 2018 55 Edison (Bataan) Cogeneration Corporation vs. Commissioner ofInternal Revenue, et. a/., G.R. Nos. 201665 and 201668, August 30, 2017; Commissioner of Internal Revenue v. Philippine National Bank, G.R. No. 180290, September 29, 2014; Commissioner of Internal Revenue v. United Salvage and Towage (Phils.J Inc., G.R. No. 197515, July 02, 2014; Dizon v. Court of Tax Appeals, et a!., G.R. No. 140944, April 30, 2008; Atlas Consolidated Mining and Development Corporation v. Commissioner of Internal Revenue, G.R. No. 145526, March 16, 2007; and Commissioner ofInternal Revenue v. Manila Mining Corporation, G.R. No. 153204, August 31, 2005.

DECISION CTA CASE NO. 10413 2018 Period Close ofthe Last Day to File pt January 01, 2018 to Taxable Quarter Administrative quarter March 31,2018 March 31,2018 Claim 2nd April 01, 2018 to June June 30, 2018 March 31, 2020 quarter 30,2018 yd July 01, 2018 to September 30, 2018 June 30, 2020 September 30, 2018 quarter October 01, 2018 to December 31, 2018 September 30, 4th December 31, 2018 2020 quarter December 31, 2020 However, pursuant to Sec. 4(z) of RA No. 11469 dated March 24, 2020,56 the statutory deadlines and timeliness for the fllling for the tax refunds were extended, to wit: "(z) l'v'Iove statutory deadlines and timelines for the filing and submission of any document, the payment of taxes, fees, and other charges required by law, and the grant of any benefit, in order to ease the burden on individuals under Community Quarantine;" To implement the above law, Revenue Regulations ("RR") No. 7-2020 dated l'v'Iarch 27, 2020 57 was issued extending the Application for VAT Credit/Refund Claims to April 30, 2020, while the later RR No. 11-2020 dated April29, 2020 further extended the deadlines for filing to May 30, 2020 or thirty (30) days from the date of the lifting of the quarantine,58 whichever comes later. Thereafter, the Inter-Agency Task Force for the Management of Emerging Infectious Diseases issued Resolution No. 40, Series of 2020 dated May 27, 2020, placing all highly urbanized cities of the National Capital Region ("NCR") under General Community Quarantine ("GCQ") beginning June 01, 2020. 56 "'AN ACT DECLARING THE EXISTENCE OF A NATIONAL EMERGENCY ARISING FROM THE CORONAVIRUS DISEASE 2019 (COVID-19) SITUATION AND A NATIONAL POLICY IN CONNECTION THEREWITH, AND AUTHORIZING THE PRESIDENT OF THE REPUBLIC OF THE PHILIPPINES FOR A LIMITED PERIOD AND SUBJECT TO RESTRICTIONS, TO EXERCISE POWERS NECESSARY AND PROPER TO CARRY OUT THE DECIDED NATIONAL POLICY AND FOR OTHER PURPOSES, otherwise known as "Bayanihan to Heal As One Act'~ 57 Implementing Section 4(z) of Republic Act No. 11469, otherwise known as "Bayanihan to Heal As One Act", particularly on the extension of statutory deadlines and timeliness for the filing and submission of any document and the payment of taxes. 58 The term "quarantine" used herein shall mean any announcement by the National Government resulting to limited operations and mobility, including, but not limited to, community quarantine, enhanced community quarantine, modified community quarantine, and general community quarantine. (Section 2, RR No. 11-2020).

DECISION CTA CASE NO. 10413 Despite the NCR still being under quarantine, RR No. 16-2020 dated June 19,2020 laid down the following filing due dates by taxpayer-claimants for VAT refund for the following taxable quarters in places declared to be in GCQ state:59 Calendar Quarter ending March 31, 2018 -July 15, 2020 Fiscal Quarter ending April 30, 2018 -July 31, 2020 Fiscal Quarter ending May 31, 2018 - August 15, 2020 Calendar Quarter endingJune 30, 2018 - August 31, 2020 Thus, petitioner may file its administrative claim until July 15,2020. Since petitioner's administrative claim covering all four (4) quarters CY 2018 was filed on June 30, 2020,60 the same was timely made, and thus, petitioner fulfilled the first requisite. Petitioner's judicial claim was timely filed. Pursuant to Section 112(C) of the NIRC of 1997, as amended by RA No. 10963, respondent shall grant a refund for creditable input taxes within ninety (90) days from the date of submission of the official receipts or invoices and other documents in support of the application. Counting ninety (90) days from petitioner's submission of its administrative claim with its supporting documents on June 30, 2020, respondent had until September 28, 2020 to act thereon. However, RA No. 11494 was signed into law on September 11, 2020.61 Section 4(tt) thereof provides: "SEC. 4. COVID-19 Response and Recovery Interventions. - Pursuant to Article VI, Section 23(2) of the Constitution, the President is hereby authorized to exercise powers that are necessary and proper to undertake and implement the following COVID-19 r response and recovery interventions: 59 RR No. 16-2020, Section 2. 60 Docket, JSFI, Stipulation of Facts, Par. 4, p. 323; Exhibits "P-11", "P-12", and "P-13", pp. 708 to 714. 61 AN ACT PROVIDING FOR COVID-19 RESPONSE AND RECOVERY INTERVENTIONS AND PROVIDING MECHANISMS TO ACCELERATE THE RECOVERY AND BOLSTER THE RESILIENCY OF THE PHILIPPINE ECONOMY, PROVIDING FUNDS THEREFOR, AND FOR OTHER PURPOSES, otherwise known as ''Bayanihan to Recover As One Act'~

DECISION CTA CASE NO. 10413 XXX XXX XXX (tt) Moving of statutory deadlines and timelines for the filing and submission of any document, the payment of taxes, fees, and other charges required by law, and the grant of any benefit, in order to ease the burden on individuals under [community quarantine.]" To implement the same, RR No. 27-2020 dated October 06, 2020 was issued. Section 4 thereof provides that the 90-day processing of VAT refund claims pursuant to Section 112(C) of the NIRC of 1997, as amended, is suspended during the effectivity of RA No. 11494 or until the next adjournment of the Eighteenth Congress on December 19, 2020. Simply stated, the 90-day processing of VAT refund claims by the BIR was suspended from September 11,2020 until December 19,2020. Nonetheless, Respondent was able to issue the denial letter on October 05,2020 which Petitioner received on November 05,2020.62 All of this happened while RA No. 11494 was still in effect (i.e., the 90-day processing of VAT refund claims was suspended). Simply put, the BIR was able to timely issue the denial letter within the 90-day period. Considering that petitioner received the said denial letter dated October 5, 2020 on November 05, 2020,63 it had until December 05, 2020-the last day of the thirty (30)-day period, within which to appeal the same before this Court. Since the present judicial claim was ftled on December 03, 2020,64 the same is likewise timely made. Such being the case, the Court finds that petitioner complied with the second requisite. Petitioner is a VAT-registered r person/entity. 62 Docket, Exhibit "P-15", p. 716; Exhibit "P-17", p. 226. 63 !d./ Exhibit "P-15", p. 716; Exhibit "P-17", p. 226. 64 I d./ pp. 7 to 27.

DECISION CTA CASE NO. 10413 Anent the third requisite, it is undisputed that petitioner is a VAT- registered person/entity, with TIN 008-817-591-000. 65 Thus, there is no question that petitioner showed compliance with the said requisite. Petitioner had zero-rated sales/receipts for the four (4) quarters of CY 2018 but only in the amount ofPhp883,293,500.00. The fourth and fifth requisites require that the taxpayer be engaged in zero- rated or effectively zero-rated sales, and for zero-rated sales under Sections 106(A)(2)(a)(1), (2) and (b), and 108(B)(1) and (2), the acceptable foreign currency exchange proceeds have been duly accounted for in accordance with BSP rules and regulations. In its Amended Quarterly VAT Returns for the four (4) quarters of CY 2018, petitioner declared total sales/receipts of Php888,563,454.98, consisting entirely of zero-rated sales/receipts, broken down as follows: CY 2018 Zero-Rated Exhibit No. 1st Quarter Sales /Receipts "P-9-2"66 2nd Quarter "P-9-4"67 3rd Quarter Php190,466,533.82 "P-9-6"68 4rh Quarter 226,742,000.00 "P-9-8"69 Total 205,575,902.06 265,779,019.10 Php888,563,454. 98 As shown in petitioner's sales schedules, the aforestated sales/receipts pertain to the following entities:70 Zero-Rated Sales/Receipts In Philippine Client In US Dollars Pesos Acyan Corporation $ 19,146.10 Php992,533.82 New Asurion Europe Limited 79,746.92 4,277,421.16 Asurion Insurance Services, Inc. 16,750,000.00 883,293,500.00 Total $16,848,893.02 Php888,563,454.98 65 Id., Par. 1, Stipulation of Facts, p. 322; Exhibit "P-3", p. 608. ;v 66 Id., p. 679. 67 Id., p. 688. 68 Id., p. 696. 69 Id., p. 703. 70 Exhibits "P-23-a" to "P-23-d".

DECISION CTA CASE NO. 10413 For the VAT zero-rating of its sales/receipts, petitioner invokes Section 1OS (B) (2) of the NIRC of 1997, as amended, which reads as follows: "SEC 108. Value-Added Tax on Sale ofServices and Use or Lease of Properties. - XXX XXX XXX (B) Transactions Sul~ject to Zero Percent (0%) Rate. - The following services performed in the Philippines by VAT- registered persons shall be subject to zero percent (0%) rate: (1) Processing, manufacturing or repacking goods for other persons doing business outside the Philippines which goods are subsequently exported, where the services are paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP); (2) Services other than those mentioned in the preceding paragraph rendered to a person engaged in business conducted outside the Philippines or to a nonresident person not engaged in business who is outside the Philippines when the services are performed, the consideration for which is paid for in acceptable foreign currency and accounted for in accordance with the rules and regulations of the Bangko Sentral ng Pilipinas (BSP);"71 Preceding from the foregoing, certain essential elements must be present for a sale or supply of services to be subject to the VAT rate of zero percent (0%), under Section 1OS(B) (2) of the NIRC of 1997, as amended, to wit: 1. The recipient of the services is a foreign corporation, and the said corporation is doing business outside the Philippines, or is a non-resident person not engaged in business who is outside the Philippines when tl1e services are performed;72 f 71 Emphasis supplied. 72 Site! Philippines Corporation (Formerly Clientlogic Phtls. Inc.) v. Commissioner of Internal Revenue, G.R. No. 201326, February 08, 2017; Commissioner of Internal Revenue v. Burmeister and Wain Scandinavian Contractor Mindanao/ Inc., G.R. No. 153205, January 22, 2007; Accenture/ Inc. v. Commissioner ofInternal Revenue, G.R. No. 190102, July 11, 2012.

DECISION CTA CASE NO. 10413 2. The services fall under any of the categories under Section 108(B)(2),73 or simply, the services rendered should be other than "processing, manufacturing or repacking goods";74 3. The service must be performed in the Philippines75 by a VAT- registered person; and 4. The payment for such services should be in acceptable foreign currency accounted for in accordance with BSP rules.76 As to thefirst essential element, in order to be considered as a non-resident foreign corporation doing business outside the Philippines, each entity must be supported, at the very least, by both a Certification of Non-Registration of Corporation/ Partnership issued by the Philippine SEC, and proof of incorporation/registration in a foreign country (e.g., Articles/ Certificate of Incorporation/ Registration and/or Tax Residence Certificate). The former establishes that the recipient of the service has no registered business in the Philippines, and that it is not engaged in trade or business within the Philippines; while the latter proves that the said recipient of the service is indeed foreign. The said documents have been consistently required by this Court for purposes of the said first essential element following Commissioner of Internal Revenue vs. Deutsche Knowledge S eroices Pte. Ltd. 77 In the present case, petitioner satisfied the first essential element, as evidenced by the following documents: Company N arne Certification of Non- Proof of incorporation/ Registration of registration in a foreign Company issued by country the SEC (Exhibit reference) (Exhibit reference) ;/ 73 Commissioner ofInternal Revenue v. American Express Internationa~ Inc. (Philippine Branch), G.R. No. 152609, June 29, 2005. 74 Commissioner ofInternal Revenue v. Burmeister and Wain Scandinavian Contractor Mindanao, Inc., G.R. No. 153205, January 22, 2007. 75 Id 76 Commissioner ofInternal Revenue v. Burmeister and Wain Scandinavian Contractor Mindanao, Inc., G.R. No. 153205, January 22, 2007; Commissioner of Internal Revenue v. American Express Internationa~ Inc. (Philippine Branch), G.R. No. 152609, June 29, 2005. 77 G.R. No. 234445, July 15, 2020.

DECISION CTA CASE NO. 10413 1. Acyan Corporation "P-7 -3"78 "P-6"79 "P-7-1 "80 "P-4"81 2. Asurion Insurance Services, Inc. However, regarding petitioner's client, New Asurion Europe Limited, the supporting SEC Certification of Non-Registration of Company82 and Articles of Association83 submitted by petitioner, bear a different name, i.e., Asurion Europe Limited. For failure to show that New Asurion Europe Limited and Asurion Europe Limited are one and the same entity, petitioner's claimed zero-rated sales to New Asurion Europe Limited in the amount Php4,277,421.16 (equivalent of US$79,746.92) shall be disallowed outright. As for the sec-ond essential element, petitioner's sales to Asurion Insurance Services, Inc. satisfactorily complied therewith, while sales to Acyan Corporation in the amount of Php992,533.82 (equivalent of US$19,146.10) must be disallowed for petitioner's failure to submit any service agreement entered into with said client. C::onsidering that only the sales to Asurion Insurance Services, Inc. in the amount of Php883,293,500.00 (equivalent of US$16,750,000.00) satisfactorily met the first and sec-ond essential elements, what is now left to be determined is whether the said sales complied with the third essential element, i.e., that services must be performed in the Philippines by a VAT-registered person. While the Service Agreement entered into by petitioner with Asurion Insurance Services, Inc. does not contain a clause that categorically states that petitioner's services will be rendered in the Philippines only, petitioner's Finance Manager, Mr. Santiago De Guzman II, testified through his Sworn Statement,84 that the services enumerated in the Service Agreement were performed in the Philippines. This was further corroborated by Mr. Jay Ballesteros, the Court- commissioned ICPA, testifying through his Sworn Statement. 85 Therefore, petitioner has satisfied the third essential element with regard to its sales to Asurion Insurance Services, Inc. in the amount ofPhp883,293,500.00 (equivalent of US$16,750,000.00~ 78 Docket, p. 671. 79 !d., p. 649 to 668. 80 !d., p. 669. 81 !d., p. 609 to 637. 82 !d., Exhibit "P-7-2", p. 670. 83 Id., Exhibit "P-5", pp. 638 to 648. 84 Id., Exhibit 17, p. 219. 8s !d., Exhibit "P-18", p. 468.

DECISION CTA CASE NO. 10413 Finally, as to the fourth essential element and in relation to the fifth requisite for the granting of the input VAT refund, petitioner presented the Certificate of Inward Remittance issued by the Bank of America, N .A., Manila Branch, showing the remittances of the foreign currency proceeds of petitioner's sales to Asurion Insurance Services, Inc. in the amount US$16,750,000.00. 86 It is noteworthy that the certification of inward remittances attests to the fact of payment ''in ac-c�eptableforeign c-urrenry . .. and ac-c-ountedfor in ac-c-ordanc-e with the rules and regulations ofthe BSP".87 In any event, the foreign currency remittances referred to under Section 108(B)(2) must not only be duly accounted for in accordance with the rules and regulations of the BSP, but must also comply with the pertinent invoicing requirements, containing all the required information under Section 113(A) and (B) of the NIRC of 1997, as amended, to wit- "SEC. 113. Invoir:ing and Ac-c-ounting Requirements for VAT- registered Persons. - (A) Invoicing Requirements. - A VAT-registered person shall 1ssue: (1) A VAT invoice for every sale, barter or exchange of goods or properties; and (2) A VAT official receipt for every lease of goods or properties, and for every sale, barter or exchange of services. (B) Information Contained in the VAT Invoic-e or VAT Offir:ial Rec-eipt. - The following information shall be indicated in the VAT invoice or VAT official receipt: (1) A statement that the seller is a VAT-registered person, followed by his Taxpayer's Identification Number (TIN); (2) The total amount which the purchaser pays or is obligated to pay to the seller with the indication that such amount includes the value-added tax: Provided, That: r 86 !d./ Exhibit " P-8", pp. 672 to 673. 87 Intel Technology Philippines/ Inc. v. Commissioner ofInternal Revenue, G.R. No. 166732, April 27, 2007.

DECISION CTA CASE NO. 10413 (a) The amount of the tax shall be shown as a separate item in the invoice or receipt; (b) If the sale is exempt from value-added tax, the term 'VAT-exempt sale' shall be written or printed prominendy on the invoice or receipt; (c) If the sale is subject to zero percent (0%) value-added tax, the term 'zero-rated sale' shall be written or printed prominendy on the invoice or receipt; (d) If the sale involves goods, properties or services some of which are subject to and some of which are VAT zero-rated or VAT-exempt, the invoice or receipt shall clearly indicate the break- down of the sale price between its taxable, exempt and zero-rated components, and the calculation of the value-added tax on each portion of the sale shall be shown on the invoice or receipt: Provided, That the seller may issue separate invoices or receipts for the taxable, exempt, and zero-rated components of the sale. (3) The date of transaction, quantity, unit cost �and description of the goods or properties or nature of the service; and (4) In the case of sales in the amount of One thousand pesos (Php1,000) or more where the sale or transfer is made to a VAT- registered person, the name, business style, if any, address and Taxpayer Identification Number (TIN) of the purchaser, customer or client." These prov1s1ons of the NIRC of 1997, as amended, are further implemented by Section 4.113-1(A) and (B) ofRR No. 16-2005, as amended, to Wlt: "SEC. 4.113-1. Invoicing Requirements. - (A) A VAT-registered person shall issue: - (1) A VAT invoice for every sale, barter or exchange of r goods or properties; and

DECISION CTA CASE NO. 10413 (2) A VAT official receipt for every lease of goods or properties, and for every sale, barter or exchange of services. Only VAT-registered persons are required to print their TIN followed by the word "VAT" in their invoice or official receipts. Said documents shall be considered as a 'VAT Invoice' or 'VAT official receipt'. All purchases covered by invoices/receipts other than VAT Invoice/VAT Official Receipt shall not give rise to any input tax. VAT invoice/official receipt shall be prepared at least in duplicate, the original to be given to the buyer and the duplicate to be retained by the seller as part of his accounting records. (B) Information contained in VAT invoice or VAT official receipt. -The following information shall be indicated in VAT invoice or VAT official receipt: (1) A statement that the seller is a VAT-registered person, followed by his TIN; (2) The total amount which the purchaser pays or is obligated to pay to the seller with the indication that such amount includes the VAT; Provided, That: (a) The amount of tax shall be shown as a separate item in the invoice or receipt; (b) If the sale is exempt from VAT, the term 'VAT- exempt sale' shall be written or printed prominently on the invoice or receipt; (c) If the sale is subject to zero percent (0%) VAT, the term 'zero-rated sale' shall be written or printed prominently on the invoice or receipt; (d) If the sale involves goods, properties or services some of which are subject to and some of which are VAT zero-rated or VAT-exempt, the invoice or receipt shall clearly indicate the break-down of the sale price between its taxable, exempt and zero-rated components, and the ;v

DECISION CTA CASE NO. 10413 calculation of the VAT on each portion of the sale shall be shown on the invoice or receipt. The seller has the option to issue separate invoices or receipts for the taxable, exempt, and zero-rated components of the sale. (3) In the case of sales in the amount of one thousand pesos (Phpl,OOO.OO) or more where the sale or transfer is made to a VAT- registered person, the name, business style, if any, address and TIN of the purchaser, customer or client, shall be indicated in addition to the information required in (1) and (2) of this Section." In addition, the sales invoices ("Sis") and official receipts ("ORs") must be duly registered with the BIR as presctibed under Section 237 in relation to Section 238 of the NIRC of 1997, as amended, to wit: "SEC. 237. Issuance ofReceipts or Sales or Commercial Invoices.- (A) Issuance. -All persons subject to an internal revenue tax shall, at the point of each sale and transfer of merchandise or for services rendered valued at One hundred pesos (PlOO) or more, issue duly registered receipts or sales or commercial invoices, showing the date of transaction, quantity, unit cost and description of merchandise or nature of service: xxx"88 "SEC. 238. Printing ofReceipts or Sales or Commercial Invoices.- All persons who are engaged in business shall secure from the Bureau ofinternal Revenue an authority to print receipts or sales or commercial invoices before a printer can print the same. No authority to print receipts or sales or commercial invoices shall be granted unless the receipts or invoices to be printed are serially numbered and shall show, among other things, the name, business style, Taxpayer Identification Number (TIN) and business address of the person or entity to use the same, and such other information that may be required by rules and regulations to be promulgated by the Secretary of Finance, upon recommendation of the CommissioneP' 88 Emphasis supplied. 89 Emphasis supplied.

DECISION CTA CASE NO. 10413 Since petitioner's reported sales are in the nature of sale of services under Section 1OS(B) (2) of the NIRC of 1997, as amended, petitioner is required to issue BIR-registered VAT O Rs for the foreign currency proceeds of each sale transaction, the infmmation contained therein must be in compliance with the applicable provisions previously cited. In the present case, the Court finds that petitioner's sales to Asurion Insurance Services, Inc. in the amount of Php883,293,500.00 (equivalent of US$1 6,750,000.00) are duly covered by BIR-registered VAT ORs which are compliant with the invoicing requirements under the NIRC of 1997, as amended, and the implementing regulations, to wit:90 E x hib it OR Date OR CLIENT Amount Conversio n Amo unt No. No. In US Rate In Philippine D ollar($) (Php) Peso (Php) 42,534,000.00 "P-26-1" 9 January OR AS URI O N 850,000.00 50.04 2018 No. INSURANCE 61,404,000.00 0119 SERVICES "P-26-2" 7 February INC. 1,200,000.00 51.17 8s,s36,ooo.oo I 2018 OR AS URI O N No. INSURANCE 70,443,000.00 "P-26-3" 8 March 0120 SERVICES 1,650,000.00 51.84 2018 INC. 57,398,000.00 OR ASURION " P-26 -5 " 6 April No. INSURANCE 1,350,000.00 52.18 98,901,000.00 2018 0121 SERVICES INC. 58,806,000.00 "P-26-6" 4May OR 1,100,000.00 52.18 2018 No. AS URI O N 79,845,000.00 0122 INSURANCE "P-26-7" 6June SERVICES 1,850,000.00 53.46 r 2018 OR INC. No. AS URI O N "P-26-8" 6 July 0123 INSURANCE 1,100,000.00 53.46 2018 SERVICES OR INC. "P-26-9" 8 August No. ASURION 1,500,000.00 53.23 2018 0124 INSURANCE SERVICES OR INC. No. 0125 ASURION INSURANCE OR SERVICES No. INC. 0126 AS URI O N INSURANCE SERVICES INC. 90 As summarized in Exhibit "P-19", Annex 1, Docket - Vol. I, p. 359.

DECISION CTA CASE NO. 10413 "P-26- 6 OR AS U R I O N 1,200,000.00 53.47 64,164,000.00 10" September No. INSURANCE 1,100,000.00 54.32 0127 SERVICES 2,150,000.00 53.57 59,752,000.00 "P-26- 2018 INC. 1'700,000.00 52.55 12" OR AS URI O N 16,750,000.00 I 9 October No. INSURANCE I "P-26- 2018 0128 SERVICES 14" INC. 115,175,500.00 6 OR AS URI O N "P-26- November No. INSURANCE 89,335,000.00 16" 0130 SERVICES 1 883,293,5oo.oo 2018 INC. OR AS URI O N 5 No. INSURANCE December 0132 SERVICES 2018 INC. Total In sum, petitioner has satisfied the fourth essential element and, consequently, tl1e fourth and fifth requisites, and has valid zero-rated sales/receipts, but only in the amount of Php883,293,500.00, representing its sales to Asurion Insurance Services, Inc. for the CY 2018. The input VAT being claimed are not transitionalinput taxes. Petitioner's input VAT claims are not transitional input taxes, as provided for under Section 111 (A) of the NIRC of 1997, as amended, to wit: "SEC. 111. Transitional/ Presumptive Input Tax Credits.- (A) Transitional Input Tax Credits.- A person who becomes liable to value-added tax or any person who elects to be a VAT- registered person shall, subject to the filing of an inventory according to rules and regulations prescribed by the Secretary of Finance, upon recommendation of the Commissioner, be allowed input tax on his beginning inventory of goods, materials and supplies equivalent to two percent (2%) of the value of such inventory or the actual value-added tax paid on such goods, materials and supplies, whichever is higher, which shall be creditable against the output tax." Transitional input tax credit operates to benefit newly VAT-registered persons, whether or not they previously paid taxes in the acquisitions of their beginning inventory of goods, materials and supplies. During the period of I'

DECISION CTA CASE NO. 10413 transition from non-VAT to VAT status, the transitional input tax credit serves to alleviate the impact of the VAT on the taxpayer.91 Since there is no showing that the claimed input taxes are transitional input VAT, petitioner has complied with the sixth requisite for the grant of an input VAT refund. Not all of petitionerJs input VAT being claimed for refund were duly substantiated. Anent the seventh requisite in claiming VAT refund, petitioner must provide supporting documents to prove that the input taxes claimed for refund for the four (4) quarters of CY 2018 were actually due or paid, pursuant to Section 11 O(A) of the NIRC, as amended, which provides: "SEC. 110. Tax Credits.- (A) Creditable input Tax.- (1) Any input tax evidenced by a VAT invoice or official receipt issued in accordance with Section 113 hereof on the following transactions shall be creditable against the output tax: (a) Purchase or importation of goods: (i) For sale; or (ii) For conversion into or intended to form part of a finished product for sale including packaging materials; or (iii) For use as supplies in the course of business; or (iv) For use as materials supplied in the sale of service; or Cof (v) For use in trade or business for which deduction for depreciation or amortization is allowed under this 91 Fort Bonifacio Development Corporation v. Commissioner of Internal Revenue, G.R. Nos. 158885 and 170680, April 02, 2008.

DECISION CTA CASE NO. 10413 (b) Purchase of services on which a value-added tax has actually been paid. (2) The input tax on domestic purchase or importation of goods or properties by a VAT-registered person shall be creditable: (a) To the purchaser upon consummation of sale and on importation of goods or properties; and (b) To the importer upon payment of the value-added tax prior to the release of the goods from the custody of the Bureau of Customs. Provided, That the input tax on goods purchased or imported in a calendar month for use in trade or business for which deduction for depreciation is allowed under this Code, shall be spread evenly over the month of acquisition and the fifty-nine (59) succeeding months if the aggregate acquisition cost for such goods, excluding the VAT component thereof, exceeds One Million pesos (P1,000,000): Provided, however, That if the estimated useful life of the capital good is less than five (5) years, as used for depreciation purposes, then the input VAT shall be spread over such a shorter period: Provided, jinal!J, That in the case of purchase of services, lease or use of properties, the input tax shall be creditable to the purchaser, lessee or licensee upon payment of the compensation, rental, royalty or fee." The above provisions are implemented by Sections 4.110-1 to 4.110-3 ofRR No. 16-2005, as amended, which provide: "SECTION 4.110-1. Credits for Input Tax. - 'Input tax' means the VAT due on or paid by a VAT-registered person on importation of goods or local purchases of goods, properties, or services, including lease or use of properties, in the course of his trade or business. It shall also include the transitional input tax and the presumptive input tax determined in accordance with Sec. 111 of the Tax Code. It includes input taxes which can be directly attributed to t transactions subject to the VAT plus a ratable portion of any input

DECISION CTA CASE NO. 10413 tax which cannot be directly atuibuted to either the taxable or exempt activity. Any input tax on the following transactions evidenced by a VAT invoice or official receipt issued by a VAT-registered person in accordance with Sees. 113 and 237 of the Tax Code shall be creditable against the output tax: (a) Purchase or importation of goods: (1) For sale; or (2) For conversion into or intended to form part of a finished product for sale including packaging materials; or (3) For use as supplies in the course of business; or (4) For use as materials supplied in the sale of services; or (5) For use in trade or business for which deduction for depreciation or amortization is allowed under the Tax Code, (b) Purchase of real properties for which a VAT has actually been paid; (c) Purchase of services in which a VAT has actually been paid. (d) Transactions "deemed sale" under Sec. 106 (B) of the Tax Code; (e) Transitional input tax allowed under Sec. 4.111 (a) of these Regulations; (f) Presumptive input tax allowed under Sec. 4.111 (b) of these Regulations; (g) Transitional input tax credits allowed under the r transitory and other provisions of these Regulations.

DECISION CTA CASE NO. 10413 SEC. 4.110-2. Persons Who Can Avail ofthe Input Tax Credit. - The input tax credit on importation of goods or local purchases of goods, properties or services by a VAT-registered person shall be creditable: (a) To the importer upon payment of VAT prior to the release of goods from customs custody; (b) To the purchaser of the domestic goods or properties upon consummation of the sale; or (c) To the purchaser of services or the lessee or licensee upon payment of the compensation, rental, royalty or fee. SEC. 4.110-3. Claim for Input Tax on Depreciable Goods. - Where a VAT-registered person purchases or imports capital goods, which are depreciable assets for income tax purposes, the aggregate acquisition cost of which (exclusive ofVAT) in a calendar month exceeds One Million pesos (P1,000,000.00), regardless of the acquisition cost of each capital good, shall be claimed as credit against output tax in the following manner: (a) If the estimated useful life of the capital good is five (5) years or more - The input tax shall be spread evenly over a period of sixty (60) months and the claim for input tax credit will commence in the calendar month when the capital good is acquired. The total input taxes on purchases or importations of this type of capital goods shall be divided by 60 and the quotient will be the amount to be claimed monthly. (b) If the estimated useful life of a capital good is less than five (5) years - The input tax shall be spread evenly on a monthly basis by dividing the input tax by the actual number of months comprising the estimated useful life of the capital good. The claim for input tax credit shall commence in the calendar month that the capital goods were acquired. Where the aggregate acquisition cost (exclusive of VAT) of the existing or finished depreciable capital goods purchased or r imported during any calendar month does not exceed one million

DECISION CTA CASE NO. 10413 pesos (Pl,OOO,OOO.OO), the total input taxes will be allowable as credit against output tax in the month of acquisition. Capital goods or properties refers to goods or properties with estimated useful life greater than one (1) year and which are treated as depreciable assets under Sec. 34(F) of the Tax Code, used directly or indirectly in the production or sale of taxable goods or serv1ces. The aggregate acquisition cost of depreciable assets in any calendar month refers to the total price, excluding the VAT, agreed upon for one or more assets acquired and not on the payments actually made during the calendar month. Thus, an asset acquired on installment for an acquisition cost of more than P1 ,000,000.00, excluding the VAT, will be subject to the amortization of input tax despite the fact tl1at the monthly payments/installments may not exceed Pl ,000,000.00. Construction in progress (CIP) is the cost of construction work which is not yet completed. CIP is not depreciated until the asset is placed in service. Normally, upon completion, a CIP item is reclassified and the reclassified asset is capitalized and depreciated. CIP is considered, for purposes of claiming input tax, as a purchase of service, the value of which shall be determined based on the progress billings. Until such time the construction has been completed, it will not qualify as capital goods as herein defined, in which case, input tax credit on such transaction can be recognized in the month the payment was made: Provided, that an official receipt of payment has been issued based on the progress billings. In case of contract for the sale of service where only the labor will be supplied by the contractor and the materials will be purchased by the contractee from other suppliers, input tax credit on the labor contracted shall still be recognized on the month the payment was made based on progress billings while input tax on the purchase of materials shall be recognized at the time the materials were purchased. (a) The amortization of the input VAT shall only be allowed until December 31, 2021 after which taxpayers with unutilized input VAT on capital goods purchased or imported shall t

DECISION CTA CASE NO. 10413 be allowed to apply the same as scheduled until fully utilized: Provided, That in the case of purchase of services, lease or use of properties, the input tax shall be creditable to the purchaser, lessee or licensee upon payment of the compensation, rental, royalty or fee. XXX XXX XXX Once the input tax has already been claimed while the construction is still in progress, no additional input tax can be claimed upon completion of the asset when it has been reclassified as a depreciable capital asset and depreciated." Relative thereto, Section 4.110-8 ofRR No. 16-2005provides for the substantiation requirements of input tax credits, as follows: "SEC. 4.110-8. Substantiation ofInput Tax Credits.- (a) Input taxes for the importation of goods or the domestic purchase of goods, properties or services is made in the course of trade or business, whether such input taxes shall be credited against zero-rated sale, non-zero-rated sales, or subjected to the 5% Final Withholding VAT, must be substantiated and supported by the following documents, and must be reported in the information returns required to be submitted to the Bureau: (1) For the importation of goods -import entry or other equivalent document showing actual payment of VAT on the imported goods. (2) For the domestic purchase of goods and properties - invoice showing the information required under Sees. 113 and 237 of the Tax Code. (3) For the purchase of real property- public instrument i.e., deed of absolute sale, deed of conditional sale, contract/ agreement to sell, etc., together with VAT invoice issued by the seller. (4) For the purchase of services- official receipt showing the information required under Sees. 113 and 237 of the Tax Code. r

DECISION CTA CASE NO. 10413 A cash register machine tape issued to a registered buyer shall constitute valid proof of substantiation of tax credit only if it shows the information required under Sees. 113 and 237 of the Tax Code." Verily, to prove entitlement to credits for input taxes due or paid, petitioner must not only present the supporting documents prescribed under Section 4.110-8 of RR No. 16-2005, but also, these documents must comply with the invoicing requirements under Sections 113(A) and (B), 237 and 238 of the NIRC of 1997, as amended, as implemented by Section 4.113-1(A) and (B) of RR No. 16-2005. For the four (4) quarters of CY 2018, petitioner reported unutilized input VAT of Php21,616,914.71 arising from its amortization of input tax on purchases of capital goods exceeding Php1Milion, domestic purchases of goods other than capital goods, domestic purchases of services, and services rendered by non-residents, which is the subject of the present claim for refund, as shown below: 1"' Quarter znd Quarter 3'd Quarter 4'h Quarter (Exhibit "P-9-2") (Exhibit "P-9- CY 2018 4") (Exhibit "P-9-6") (Exhibit "P-9-8") Input tax Php8,926,236.51 Php8,405,290.39 Php7,705,883.19 Php7,076,596.46 Php8,926,236.51 deferred on capital goods 597,196.80 577,671.43 546,593.08 412,937.15 2,134,398.46 exceeding P h p 1Million 8,405,290.39 7,705,883. 19 7,076,596.46 6,429,585.01 6,429,585.01 from previous Php1,118,142.92 Php1,277,078.63 Php1,175,879.81 Php1,059,948.60 Php4,631,049.96 quarter Add: r' Purchases of capital goods exceeding Php1Million this quarter Lw: Input tax on purchases of capital goods exceeding Php1Million deferred for the succeeding period Amortization of input tax

DECISION CTA CASE NO. 10413 on capital 106,723.31 335,011.04 280,454.19 523,909.75 1,246,098.29 goods 3,314,938.95 exceeding 2,778,311.84 3,241,061.39 6,390,788.22 15,725,100.40 Php1Million 14,666.06 this quarter - - - 14,666.06 Add: Input VAT from 1,118,142.92 1,277,078.63 1,175,879.81 1,059,948.60 4,631,049 .96 Current Transactions: Php4,003,178.07 Php4,853,151.06 Php4,785,939.01 Php7,974,646.57 Php21,616,914.71 Domestic purchases of goods other than capital goods Domestic purchases of serviCes Services rendered by non-residents Amortization of Input Tax from Purchases of Capital Good exceeding P1 Million Excess and unutilized input tax Upon examination of petitioner's input VAT claim and the related supporting documents, the Court-commissioned ICPA, SGV & Co., in its Report dated April18, 2022, recommended the disallowance of the following input taxes totalling Php6,547,175.06, detailed as follows: 92 Exhibit No. Reference Description Amount Input VAT from Domestic Purchases of Goods and Services "P-29" and Input VAT from domestic purchases of Php 550,276.10 A"Pn-n1e9x"4' goods supported by VAT invoices and domestic purchases of services supported by VAT ORs dated outside of calendar year 2018 "P-30" and Input VAT from domestic purchases of 107,550.41 "P-19" goods supported by VAT invoices and Annex 5' domestic purchases of services 92 Docket, Exhibit "P-19", pp. 13 to 14, pp. 355 to 356. r

DECISION CTA CASE NO. 10413 "P-31" and supported by VAT ORs that are 439.29 A"Pn-n1e9x"6' undated/ with incomplete date 149,283.57 Input VAT from domestic purchases of "P-32" and goods supported by VAT invoices and ' "P-19", domestic purchases of services Annex 7 supported by VAT ORs with no valid 123,742.60 ATP "P-33" and Input VAT from domestic purchases of 225,347.12 A"Pn-n1e9x"8' goods supported by VAT invoices and domestic purchases of services 374,080.15 "P-34" and supported by VAT ORs with " P - 19 " incorrect/ missing/ incomplete 1,833.44 Annex 9' Company's name 1,648.04 Input VAT from domestic purchases of 21,273.99 "P-35" and goods supported by VAT invoices and A"nPn-e1x9"1'0 domestic purchases of services ~ supported by VAT ORs with "P-36" and i n c o r r e c t / m i s s i n g / incomp lete "P-19", Company's TIN Annex 11 Input VAT from domestic purchases of goods supported by VAT invoices and "P-37" and domestic purchases of services A"nPn-e1x9"1'2 supported by VAT ORs with i n c o r r e c t / m i s s i n g / in c o m p lete "P-38" and Company's registered address "P-19", Input VAT from domestic purchases of Annex 13 goods supported by VAT invoices and domestic purchases of services supported by VAT ORs where amount of VAT is not separately shown/incorrecdy shown Input VAT from domestic purchases of goods supported by VAT invoices and domestic purchases of services supported by VAT ORs that are not original copies Input VAT from domestic purchases of goods supported by VAT invoices and domestic purchases of services supported by VAT ORs with corrections but without countersignature Input VAT from domestic purchases of goods supported by VAT invoices and domestic purchases of services

DECISION CTA CASE NO. 10413 supported by VAT ORs with unreadable details "P-39" and Input VAT from domestic purchase of 675,725.76 A"nPn-e1x9"1'4 goods without VAT invoices and domestic purchases of services without "P-19" ' VAT ORs but supported by other 71,275.14 Annex 15 documents Input VAT from domestic purchases of goods and domestic purchases of services not supported by any documents Input VAT from Amortization of Input Tax on Capital Goods exceeding Phpl,OOO,OOO- Current Purchases 2,337.50 �p-44" and Amortized input VAT from purchases A"nPn-e1x9"2'0 of capital goods exceeding :P1 ,000,000 supported by VAT invoices that are not original copies "P-45" and Amortized input VAT from purchases 2,725 .00 "P-19", of capital goods exceeding P.1 ,000,000 Annex 21 supported by VAT invoices that are undated "P-46" and Amortized input VAT from purchases 4,981.18 "P-19". of capital goods exceeding :P1 ,000,000 Annex 22 not supported by VAT invoices Input VAT from Amortization of Input Tax on Capital Goods exceeding Ph Jl,OOO,OOO -Purchases from Prior Periods A"nPn-e1x9 "2'3 Amortized input VAT from purchases 2,932,992.89 of capital goods exceeding :P1 ,000,000 supported by original copies ofVAT invoices issued in the name of the Company with complete TIN, address, valid ATP and are dated in the same quarter when the initial input VAT amortization was claimed based on the 2017 ICPA report (CTA Case No. 10121) "P-19". Amortized input VAT from purchases 727,452.17 Annex 24 of capital goods exceeding :P1,000,000 not supported by VAT invoices based on the 2017 ICPA report (CTA Case No . 10121) A"nPn-e1x9"2'5 Amortized input VAT from purchases 574,210.71 of capital goods exceeding :P1,000,000 supported by VAT invoices but have ~ issues on invoicing requirements (e.g., ~�

DECISION CTA CASE NO . 10413 TIN, address and ATP) based on the P h p 6 , 5 4 7 ,175.06 2017 ICPA report (CTA Case No. 10121) Total The Court agrees that the above input VAT of Php6,547,175.06 must be disallowed for failure to comply with the invoicing and substantiation requirements under the VAT law and regulations. In addition, input VAT in the amount of Php11,892,007 .95 shall be disallowed for the following reasons: Exhibit No. Date Invoice No. Tax Base Input VAT I OR No. Name of Supplier 23.57 1) Purchases ofservices supported by VAT ORs but the nature ofthe services is 351.43 325.68 not indicated thereon 365.35 77 5.17 "P-27-131" 15 February OR No.2- AYALA PROPERTY 196.42 1,218.00 300.00 2018 01281331 MANAGEMENT 396.00 396.00 CORP 39,542.77 38,423.14 "P-27-133" 10 January OR No. 4167 BV CUISINE INC 2,928.58 480.97 2018 489 .01 "P-27-134" 18 January OR No. 4195 BV CUISINE INC 2,714.00 505 .08 2018 r "P-27-135" 24 Januaty OR No. 4224 BV CUISINE INC 3,044.58 2018 "P-27-136" 28 Februaty OR No. 4356 BV CUISINE INC 6,459.75 2018 "P-27-139" 26 January OR No. 2979 Continental Rental & 10,150.00 2018 Tours. Inc. "P-27-139" 26 January OR No. 2979 Continental Rental & 2,500.00 2018 Tours. Inc. "P-27-139" 26 Januaty OR No. 2979 Continental Rental & 3,300.00 2018 Tours. Inc. "P-27-139" 26 January OR No. 2979 Continental Rental & 3,300.00 2018 Tours. Inc. "P-27-150" 14 Februaty OR No. GLOBE TELECOM 329,523.08 2018 3543684 "P-27-151" 14 March OR No. GLOBE TELECOM 320,192.83 2018 3556544 "P-27-152" 19 Februaty OR No. INNOVE 4,008.08 2018 0786215 COMMUNICATION S INC "P-27-153" 14 Februaty OR No. INNOVE 4,075.08 2018 0782139 COMMUNICATION S INC "P-27-154" 14 March OR No. INNOVE 4,209.00 2018 0796167 COMMUNICATION - - -�- S INC

DECISION CTA CASE NO. 10413 "P-27 -155" 2 March OR No. INTELLICARE 45,837.00 5,500.44 "P-27 -156" 2018 0021426 38,763 .75 4,651.65 "P-27-156" OR No. INTELLICARE 10,688.92 1,282.67 "P-27 -156" 13 March 0022027 "P-27-156" 2018 OR No. INTELLICARE 7,428.92 891.47 "P-27-156" 0022027 6,5 15.17 781.82 "P-27 -156" 13 March OR No. INTELLICARE 10,688.92 1,282.67 "P-27-156" 2018 0022027 33,791.83 4,055.02 "P-27-156" OR No. INTELLICARE 108.00 "P-27 -165" 13 March 0022027 900.00 "P-27 -169" 2018 OR No. INTELLICARE 600.00 72.00 "P-27 -170" 0022027 235,000.00 28,200.00 "P-27-171" 13 March OR No. INTELLICARE 1,320.00 "P-27-1 72" 2018 0022027 4,400.00 158.40 "P-27-173" OR No. INTELLICARE 1,320.00 528.00 "P-27-180" 13 March 4,400.00 158.40 "P-27 -180" 2018 0022027 INTELLICARE 4,400.00 528.00 "P-27-181" 154,880.00 528.00 "P-27 -181" 13 March OR No. Monster com 5,142,521.08 18,585 .60 "P-27-181" 2018 0022027 Philippines 154,969.25 617,102.53 "P-27-182" OR No. RAJAH TRAVEL 821,418 .25 18,596.31 "P-27 -182" 13 March 0002059 CORPORATION 5,142,521.08 98,570 .19 "P-27 -182" OR No. RAJAH TRAVEL 822,194.50 617,102 .53 "P-27 -184" 2018 121497 CORPORATION 155,813 .92 98,663.34 OR No. RAJAH TRAVEL 5,142,521.08 18,697.67 13 March 123683 CORPORATION 2,812.50 617,102.53 2018 OR No. RAJAH TRAVEL 337.50 125774 CORPORATION 28 March OR No. RAJAH TRAVEL 2018 127244 CORPORATION OR No. TESORO ALEGRE 8 Januaq 127245 INC 2018 OR No. TESORO ALEGRE 0002172 INC 31 Januaty OR No. TESORO ALEGRE 2018 0002172 INC OR No. TESORO ALEGRE 22 Februaty 0002224 INC 2018 OR No. TESORO ALEGRE 0002224 INC 7 March OR No. TESORO ALEGRE 2018 0002224 INC OR No. TESORO ALEGRE 7 March 0002270 INC 2018 OR No. TESORO ALEGRE 0002270 INC 24 Januaq OR No. THE REAL 2018 0002270 AMERICAN OR No. DOUGHNUT 24 Januaq 0005829 COMPANY INC 2018 THE REAL OR No. AMERICAN 22 Februaty 0007162 2018 22 Februaq 2018 22 February 2018 28 March 2018 28 March 2018 28 March 2018 15 Januaq 2018 "P-27-188" 8 March 2,535.75 304.29 2018 r

DECISION CTA CASE NO. 10413 "P-27 -191" 8 March OR No. DOUGHNUT 27,994.17 3,359.30 "P-27-195" 2018 13884 COMPANY INC 920.50 110.46 "P-27-197" OR No. 0837 Valium Security 611.58 73.39 "P-27 -198" 2 May 2018 Services Corp. 237.86 "P-27-200" OR No. ADAMANTIUM 1,982.17 133.72 "P-27 -201" 3 April 0020185 GROUP PHILS INC 1,114.33 39.64 "P-27 -202" 2018 OR No. BEYOND 68.04 19 April 0002587 CONCEPTS INC 330.33 "P-27 -203" 2018 OR No. BISTRO ITALIANO 567.00 124.29 12 April CORP "P-27 -204" 2018 15703 BV CUISINE INC 1,035.75 73.93 "P-27 -205" 4 May 2018 OR No. 91.60 "P-27 -206" 18603 BV CUISINE INC 616.08 295.70 "P-27 -209" 7 May 2018 OR No. 0976 763.33 335.36 "P-27-210" BV CUISINE INC 2,464.17 431.79 "P-27 -211" 8 May 2018 OR No. 0984 BV CUISINE INC 2,794.67 167 .68 "P-27-212" BV CUISINE INC 3,598.25 167.68 "P-27-215" 9 May 2018 OR No. 0992 BV CUISINE INC 1,397.33 7,493.88 "P-27-215" 24May OR No. 1067 1,397.33 2,346.00 "P-27-215" 2018 62,449.00 633 .60 "P-27-215" 22 May OR No. 1054 BV CUISINE INC 19,550.00 686.40 "P-27-215" 2018 5,280.00 580.80 "P-27-215" 30 April OR No. CIGNAL TV INC 5,720.00 594.00 "P-27-215" 2018 3735424 4,840.00 594.00 "P-27-215" 30 April OR No. CIGNAL TV INC 4,950.00 646.80 "P-27-215" 2018 3735423 4,950.00 646.80 "P-27-215" 20 June OR No. CIGNAL TV INC 5,390.00 396.00 "P-27-215" 2018 3880356 5,390.00 366.00 20 June OR No. CIGNAL TV INC 3,300.00 2018 3880357 3,050.00 r 18 May OR No. 3611 Continental Rental & 2018 Tours . Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc. 18 May OR No. 3611 Continental Rental & 2018 Tours. Inc.

DECISION CTA CASE NO. 10413 "P-27 -215" 18 May OR No. 3611 Continental Rental & 4,050.00 486.00 "P-27-215" 2018 Tours. Inc. 4,510.00 541.20 "P-27-215" OR No. 3611 Continental Rental & 20,180.00 2,421.60 "P-27 -215" 18 May Tours. Inc. 5,940.00 712.80 "P-27-215" 2018 OR No. 3611 Continental Rental & 3,300.00 396 .00 " P- 27 -215" Tours. Inc. 3,450.00 414.00 "P-27 -215" 18 May OR No. 3611 Continental Rental & 3,300.00 396.00 "P-27-215" 2018 Tours. Inc. 3,950.00 474.00 "P-27-215" OR No. 3611 Continental Rental & 2,950.00 354.00 "P-27-2 15 " 18 May Tours. Inc. 3,300.00 396.00 "P-27 -215 " 2018 OR No. 3611 Continental Rental & 3,050.00 366 .00 "P-27-215" Tours. Inc. 3,300.00 396 .00 "P-27 -215" 18 May OR No. 3611 Continental Rental & 3,550.00 426.00 "P-27 -215" 2018 Tours. Inc. 3,300.00 396.00 "P-27 -215" OR No. 3611 Continental Rental & 5,720.00 686.40 "P-27 -221" 18 May Tours. Inc. 1,716.67 206.00 2018 OR No. 3611 Continental Rental & "P-27 -230" Tours. Inc. 3,974.67 476.96 18 May OR No. 3611 Continental Rental & "P-27 -230" 2018 Tours. Inc. 835,900.00 100,308.00 OR No. 3611 Continental Rental & "P-27 -231" 18 May Tours. Inc. 4,287.08 514.45 OR No. 3611 Continental Rental & "P-27 -231" 2018 Tours. Inc. 87,000.00 10,440.00 OR No. 3611 Continental Rental & "P-27-232" 18 May Tours. Inc. 43,887.50 5,266.50 "P-27 -233" 2018 OR No. 3611 Continental Rental & 11,835.25 1,420.23 "P-27 -233" Tours. Inc. 18,007.92 2,160 .95 18 May OR No. 3611 Continental Rental & 2018 Tours . Inc. t OR No. EMPIRE 18 May 001526 AUTOMATION 2018 PHILIPPINES INC OR No. INNOVE 18 May 0804698 COMMUNICATION 2018 S INC OR No. INNOVE 18 May 0804698 COMMUNICATION 2018 S INC OR No. INNOVE 18 May 0817211 COMMUNICATION 2018 S INC OR No. INNOVE 18 May 0817211 COMMUNICATION 2018 S INC OR No. INTELLICARE 19 April 0018518 2018 OR No. INTELLICARE 0018516 5 May 2018 OR No. INTELLICARE 0018516 5 May 2018 1 June 2018 1 June 2018 6 June 2018 6 June 2018 6 June 2018

DECISION CTA CASE NO . 10413 "P-27-233" 6 June 2018 OR No. INTELLICARE 14,980.75 1,797.691 "P-27-233" 6 June 2018 0018516 24,941.42 2,992.97 "P-27-233" 6 June 2018 OR No. INTELLICARE "P-27-233" 6 June 2018 0018516 7,090. 58 850.87 "P-27-233" 6 June 2018 OR No. INTELLICARE 7,890 .17 "P-27-233" 6 June 2018 0018516 3,545.33 I "P-27-233" 6 June 2018 OR No. INTELLICARE 3,545.33 I "P-27-233" 6 June 2018 0018516 3,945.08 "P-27-233" 6 June 2018 OR No. INTELLICARE 3,545.25 946.82 I "P-27-233" 6 June 2018 0018516 7,490.42 425.44 "P-27-233" 6 June 2018 OR No. INTELLICARE 6,002.67 425.44 "P-27-233" 6 June 2018 0018516 12,470.67 473.41 "P-27-233" 6 June 2018 OR No. INTELLICARE 3,945.08 425.43 "P-27-233" 6 June 2018 0018516 4,430.50 898.85 "P-27-233" 6 June 2018 OR No. INTELLICARE 9,289.42 720.32 "P-27-233" 6 June 2018 0018516 INTELLICARE 4,430.58 1,496.48 "P-27-233" 6 June 2018 OR No. 9,289.42 473.41 "P-27-233" 6 June 2018 0018516 INTELLICARE 4,430.58 531.66 "P-27-233" 6 June 2018 OR No. 13,291.58 1,114.73 "P-27-233" 6 June 2018 0018516 INTELLICARE 18,578.83 531.67 "P-27-233" 6 June 2018 OR No. 14,148.33 1,114.73 "P-27-233" 6 June 2018 0018516 INTELLICARE 8,861.08 531.67 "P-27-233" 6 June 2018 OR No. 7,798.33 1,594.99 "P-27-233" 6 June 2018 0018516 INTELLICARE 8,861.08 2,229.46 "P-27-234" 6 June 2018 OR No. 3,300.00 1,697.80 "P-27-234" 6 June 2018 0018516 INTELLICARE 5,144.42 1,063.33 OR No. 5,144.42 935.80 0018516 INTELLICARE 1,063.33 OR No. 396.00 0018516 INTELLICARE 617.33 OR No. 617.33 0018516 INTELLICARE OR No. r 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018516 INTELLICARE OR No. 0018515 INTELLICARE OR No. 0018515 .. -

DECISION CTA CASE NO. 10413 "P-27 -234" 6 June 2018 OR No. INTELLICARE 5,144.42 617.33 "P-27 -234" 6 June 2018 0018515 5,144.42 617 .33 "P-27 -234" 6 June 2018 OR No. INTELLICARE 12,986.67 1,558.40 "P -27 -234" 6 June 2018 0018515 16,947.75 2,033.73 "P-27 -234" 6 June 2018 OR No. INTELLICARE 10,288.92 1,234.67 "P-27 -234" 6 June 2018 0018515 10,288.92 1,234.67 "P-27-234" 6 June 2018 OR No. INTELLICARE 8,742.50 1,049.10 "P-27 -234" 6 June 2018 0018515 28,670.83 3,440.50 "P-27 -234" 6 June 2018 OR No. INTELLICARE 135,459.92 16,255.19 "P-27 -235" 6 June 2018 0018515 41,579.42 4,989.53 "P-27 -252" OR No. INTELLICARE 98,150 .33 11,778.04 19 April 0018515 "P-27 -252" 2018 OR No. INTELLICARE 97,372 .83 11,684.74 0018515 "P-27 -252" 19 April OR No. INTELLICARE 73,278.17 8,793 .38 2018 0018515 " P-27 -252" OR No. INTELLICARE 10,426.67 1,251.20 19 April 0018515 "P-27 -2 53" 2018 OR No. INTELLICARE 10,426.67 1,251.20 0018517 "P-27-253" 19 April OR No. OLIVE 11,228.67 1,347.44 2018 0007464 MAINTENANCE "P-27 -253" SERVICES INC 104,182.00 12,501.84 9 May 2018 OR No. OLIVE "P-27 -258" 0007464 MAINTENANCE 7,589.25 910.71 9 May 2018 SERVICES INC "P-27 -258" OR No. OLIVE 7,589.25 910.71 9 May 2018 0007464 MAINTENANCE "P-27 -259" SERVICES INC 1,320.00 158.40 1 June 2018 OR No. OLIVE - -- 0007464 MAINTENANCE 1- 1 June 2018 SERVICES INC OR No. OLIVE 10 April 0007481 MAINTENANCE 2018 SERVICES INC OR No. OLIVE 0007481 MAINTENANCE SERVICES INC OR No. OLIVE 0007481 MAINTENANCE SERVICES INC OR No. 8853 PROPERTY MAINTENANCE OR No. 8853 AND GARDENS INC OR No. P R O P E RTY 130479 MAINTENANCE AND GARDENS INC RAJAH TRAVEL CORPORATION

DECISION CTA CASE NO . 10413 "P-27 -260" 11 April OR No. RAJAH TRAVEL 1,320.00 158.40 "P-27-261" 2018 130575 CORPORATION 1,320.00 158.40 "P-27 -262" OR No. RAJAH TRAVEL 1,320.00 158.40 "P-27-275" 20 April 129278 CORPORATION 1,238.67 148.64 2018 OR No. RAJAH TRAVEL 130978 CORPORATION 13 April OR No. SHAK.EYS PIZZA 2018 0001168 ASIA VENTURES INC 12 April OR No. TESORO ALEGRE 2018 0002371 INC OR No. TESORO ALEGRE "P-27-280" 25June 0002371 INC 955,340.33 114,640.84 "P-27 -280" 2018 OR No. TESORO ALEGRE 787,348.58 94,481.83 "P-27 -280" 0002371 INC 152,800.00 18,336 .00 "P-27 -280" 25 June OR No. TESORO ALEGRE 5,142,521.08 617,102.53 "P-27 -290" 2018 0002371 INC OR No. TKKK 7,285.33 874.24 25 June 0169271 RESTAURANT 2018 CORPORATION OR No. UB IX 25June 0109689 2018 OR No. UBIX 0109689 7June2018 OR No. Valium Security 140666 Services Corp. "P-27 -292" 22 May OR No. Valium Security 7,806.75 936.81 "P-27 -292" 2018 140666 Services Corp. 9,127.08 1,095.25 "P-27 -293" OR No. Valium Security 25,259.50 3,031.14 "P-27-293" 22May 140666 Services Corp. 29,147.67 3,497.72 "P-27 -293" 2018 OR No. Valium Security 31 ,090.83 3,730.90 "P-27 -294" Services Corp. 1,165.67 " P -27- 295" 19 April 14158 Valium Security 29,147 .67 139.88 "P-27-295" 2018 OR No. Services Corp. 29,147.67 3,497 .72 "P-27-295" 14176 Valium Security 29,860.42 3,497 .72 "P-27-29 5" 19 April OR No. Services Corp. 27,994.17 3,583 .2 5 "P-27-295" 2018 14176 Valium Security 27,994.17 3,359.30 "P-27-29 5" OR No. Services Corp. 31,090.83 3,359 .30 "P-27-29 5" 19 April 14176 Valium Security 3,730.90 "P-27-29 5" 2018 OR No. Services Corp. 582.92 "P-27 -29 7" 141 76 Valium Security 29 ,147 .67 69 .9 5 18 May OR No. Services Corp. 25,189 .92 3,497.72 2018 14176 Valium Security 74,873.42 3,022. 79 OR No. Services Corp. 8,984.81 14 June Valium Security 2018 14176 Services Corp. OR No. Valium Security 14 June 14176 Services Corp. 2018 OR No. Volenday inc 14176 14 June OR No. Volenday inc 2018 0001838 OR No. 14 June 0001838 2018 14 June 2018 14June 2018 14 June 2018 14June 2018 7 June 2018 "P-27-297" 7 June 2018

DECISION CTA CASE NO. 104 13 "P-27 -297" 7 June 2018 OR No. Volenday inc 67,277.25 8,073.27 " P -27 -297" 0001838 59,541.83 7,145.02 "P-27 -297" 7 June 2018 OR No. Volenday inc 59,541.83 7,145.02 "P-27 -300" 0001838 "P-27 -301" 7 June 2018 OR No. Volenday inc 4,329.50 519.54 "P-27 -304" 0001838 2,10 1. 75 252.21 29 May OR No. YELLOW CAB 720,000.00 86,400.00 "P-27 -305" 2018 FOOD CORP 09237 YELLOW CAB 6,562.50 787.50 "P-27-311" 27 April OR No. FOOD CORP "P-27 -312" 2018 09158 ALIMAKATI 745.50 89.46 4 OR No. HOTEL PROPERTY 1,443.83 173.26 "P-27 -313" 0045613 INC FAIRMONT "P-27-3 14" September RAFFLES HOTEL 4,084. 58 490.15 " P-27 -316" 20 18 OR No. MAKATI 9,508.75 1,141.05 "P-27-3 17" 1,799.08 "P-27-318" 6 0013279 ALVIN BENEDICT 1,397.33 215.89 "P-27-319" September 1,799.08 167.68 "P-27 -320" B l'YIAGPANTAY 1,397 .33 215.89 2018 1,397 .33 167.68 " P-27-321" 12 July OR No. 0096 BV CUISINE INC 167 .68 2018 1,799.08 "P-27-326" OR No. 2669 BV CUISINE INC 215 .89 "P-27-327" 18 110,514.00 "P-27 -328" September OR No. 2508 BV CUISINE INC 11,800.00 13,261.68 1,416.00 "P-27 -336" 2018 OR No. 2532 BV CUISINE INC 100,272.83 12,032.74 13 August OR No. CIGNAL TV INC ' 5,000.00 600.00 2018 4672995 16 August OR No. CIGNAL TV INC 2018 4672993 22 August OR No. CIGNAL TV INC 4672994 2018 OR No. CIGNAL TV INC 22 August 4672992 OR No. CIGNAL TV INC 2018 4674622 22 August OR No. CIGNAL TV INC 2018 4674623 22 August OR No. Delta Neosolutions Inc 2018 14717 Delta Neosolutions Inc 25 OR No. Delta Neosolutions Inc 14716 September OR No. 2018 14838 25 OR No. EMPIRE September 001574 AUTOMATION 2018 PHILIPPINES INC 17 August 2018 17 August 2018 28 Septemb er 20 18 17 July 2018

DECISION CTA CASE NO. 104 13 "P-27 -336" 17 July OR No. E MPIRE 6,400.50 768 .06 2018 001574 AUTOMATION 1,134.00 136.08 PHILIPPINES INC 28,144.33 3,377.32 "P-27 -336" 17 July OR No. EMPIRE 336,486.08 40,378.33 2018 001574 AUTOMATION 38 1,354.08 45,762.49 PHILIPPINES INC 89,300.00 10,716.00 "P-27-337" 16 August OR No. EMPIRE 11 8.93 2018 001590 AUTOMATION 99 1.08 10,440.00 PHILIPPINES INC 87,000.00 10,440.00 "P-27 -340" 25 July OR No. GLOBE TELECOM 87,000 .00 696.00 "P-27 -340" 2018 3650328 INC 419.10 "P-27-341" 25 July OR No. GLOBE TELECOM 5,800.00 419 .10 " P -27 -344" 2018 3650328 INC 3,492.50 954.72 OR No. GMJoe Logistics 3,492.50 209.55 " P -27 -345" 4 0000071 Corp. 7,956.00 477 .36 September 1,746.25 209.55 OR No. HOBINGSULK 3,978.00 5,304.1 1 2018 0001499 CAFE INC 1,746.25 11,720.47 44,200.92 4 OR No. INNOVE 97,670 .58 r September 0906763 COMMUNICATION S INC 2018 OR No. INNOVE 8 August 08961 10 COMMUNICATION S INC 2018 OR No. INTELLICARE 0030857 "P-27 -346" 17 INTELLICARE "P-27 -34 7" September OR No. "P-27-347" 0030857 INTELLICARE "P-27-347" 2018 " P -27 -34 7" 3 OR No. INTELLICARE "P-27 -34 7" 0030857 "P-27-347" September INTELLICARE "P-27-347" 2018 OR No. "P-27-348" 3 0030857 INTELLICARE "P-27 -358" September OR No. INTELLICARE 20 18 0030857 3 INTELLICARE OR No. September 0030857 OLIVE 2018 MAINTENANCE 3 OR No. SERVICES INC 0030857 September 2018 OR No. 3 0030858 September OR No. 2018 0007564 3 September 2018 3 September 2018 3 September 2018 20 July 2018

DECISION CTA CASE NO . 104 13 "P-27 -358" 20 July OR No. OLIVE 9,624.58 1,154.95 2018 0007564 MAINTENANCE 97,670.58 11,720.47 SERVICES INC "P-27 -358" 20 July OR No. OLIVE 1,612.92 193 .55 2018 0007564 MAINTENANCE 11,429.25 1,37 1. 51 SERVICES INC 99,576.42 11,949.17 "P-27 -358" 20 July OR No. OLIVE 2018 0007564 MAINTENANCE 620.33 74.44 SERVICES INC 10,667.25 1,280.07 "P-27-358" 20 July OR No. OLIVE 104,086.67 12,490.40 2018 0007564 MAINTENANCE SERVICES INC 3,052.17 366.26 " P -27 -358" 20 July OR No. OLIVE 11,479.33 1,377.52 2018 0007564 MAINTENANCE 97,376.83 11,685.22 SERVICES INC 10,426.67 1,251.20 "P-27 -358" 20 July OR No. OLIVE 83,452.08 10,014.25 2018 0007564 MAINTENANCE 69,512.92 8,341.55 SERVICES INC 70,508.67 8,461.04 "P-27 -358" 20 July OR No. OLIVE 97,670.58 11,720.47 2018 0007564 MAINTENANCE 10,426.67 1,251.20 SERVICES INC "P-27 -358" 20 July OR No. OLIVE r 2018 0007564 MAINTENANCE SERVICES INC " P-27 -358" 20 July OR No. 2018 0007564 OLIVE MAINTENANCE "P-27 -358" 20 July OR No. SERVICES INC 2018 0007564 OLIVE MAINTENANCE "P-27-358" 20 July OR No. SERVICES INC 2018 0007564 OLIVE MA IN T E N A N C E " P -27 -358" 20 July OR No. SERVICES INC 2018 0007564 OLIVE iviAINTENANCE " P -27 -358" 20 July OR No. SERVICES INC 2018 0007564 OLIVE MA IN T E N A N C E "P -27-358" 20 July OR No. SERVICES INC 2018 0007564 OLIVE MAINTENANCE "P-27-358" 20 July OR No. SERVICES INC 2018 0007564 OLIVE MAINTENANCE " P -27 -359" 5 OR No. SERVICES INC "P-27 -359" OLIVE September 0007615 MAINTENANCE SERVICES INC 2018 OLIVE MAINTENANCE 5 OR No. SERVICES INC September 0007615 20 18 -

DECISION CTA CASE NO. 10413 "P-27-359" 5 OR No. OLIVE 6,069 .67 728.36 1 September 00076 15 MAINTENANCE 2,400.00 288.00 I SERVICES INC 2,400.00 288 .00 2018 OR No. Philscan Travel and 2,900.00 "P-27 -362" 7 0170 512 Tours Inc 2,400.00 348.00 4,800.00 288.00 " P- 27 -362" Septemb er OR No. Philscan Travel and 2,400.00 576 .00 2018 0170512 Tours Inc 2,400 .00 288.00 " P -27 -362" 7 4,800.00 288.00 OR No. Philscan Travel and 1,500 .00 576.00 "P-27-362" September 0170512 Tours Inc 2,400.00 180.00 20 18 1,200.00 288 .00 "P-27 -362" 7 OR No. Philscan Travel and 1,200.00 144.00 0170512 Tours Inc 7,589.2 5 144.00 "P-27 -362" Sep tember 910.71 2018 OR No. Philscan Travel and 7,589.25 "P-27 -362" 7 Tours Inc I 01705 12 16,07 1.42 " P -27 -363" September Philscan Travel and 152,800.00 910.71 " P -27 -363" 2018 OR No. Tours Inc 5, 142,52 1. 08 "P-27-363" 7 0170512 745,775.75 1,928.57 " P-27 -363" Philscan Travel and 18,336.00 "P-27 -363" September OR No. Tours Inc 617, 102.53 "P-27 -364" 2018 89,493.09 7 0170512 Philscan Travel and Tours, Inc. September OR No. Philscan Travel and 2018 0169749 Tours, Inc. 7 OR No. Philscan Travel and 0169749 Tours, Inc. September OR No. Philscan Travel and 20 18 0169749 Tours, Inc. OR No. Philscan Travel and 20 July 0169749 Tours, Inc. 2018 OR No. PROPERTY 0169749 MA IN T E N A N C E 20 July OR No. AND GARDENS 2018 INC 09030 PROPERTY 20 July MAINTENANCE 2018 OR No. AND GARDENS 09030 INC 20 July RGMANABAT AND 2018 OR No. COMPANY 20 July 0021540 2018 TESORO ALEGRE OR No. INC 10 0002405 TESORO ALEGRE September OR No. INC 0002405 TESORO ALEGRE 2018 OR No. INC 0002458 "P-27 -364" 10 Septemb er 2018 " P- 27-367" 26 September "P-27-376" "P-27-376" 2018 "P-27 -3 77" 26 July 2018 26 July 2018 24 August 20 18

DECISION CTA CASE NO. 10413 "P-27 -3 77" 24 August OR No. TESORO ALEGRE 725,371.67 87,044.60 "P-27-377" 2018 0002458 INC 152,844.67 18,341.36 " P- 27 -3 77" OR No. TESORO ALEGRE 5,258,091.17 630,970.94 "P-27-378" 24 August 0002458 INC 163,006.42 19,560.77 "P-27 -3 78" 2018 OR No. TESORO ALEGRE "P-27 -3 78" 0002458 INC -4,000.00 -480.00 "P-27 -390" 24 August OR No. TESORO ALEGRE 643,972.57 "P-27 -393" 2018 0002492 INC 5,3 66 ,438.08 26 6,428.58 771.43 "P-27 -399" OR No. TESORO ALEGRE "P-27-400" September 0002492 INC 461,619.92 55,394.39 "P-27 -401" 2018 "P-27 -402" 26 OR No. TESORO ALEGRE "P-27 -403" 0002492 INC "P-27-404" Sep tember "P-27 -405" 2018 OR No. 360AEVENT 544.67 65.36 "P-27-407" 26 0006908 MANAGEMENT 2,865.25 343.83 "P-27 -408" OR No. CORP 1,111.67 133.40 "P-27 -409" September 0045637 ALI MAI<ATI 11,957.92 1,434.95 2018 HOTEL PROPERTY 4,910.58 589.27 18 OR No. 3528 INC FAIRMONT 1,70 5. 83 204.70 RAFFLES HOTEL 11,957.92 1,434.95 December MAI<ATI 1,397.33 167.68 2018 BV CUISINE INC 1,799.08 215.89 5 1,397.33 167.68 OR No. 3470 BV CUISINE INC November r 2018 OR No. 4631 BV CUISINE INC 18 October OR No. 4635 BV CUISINE INC 2018 OR No. 4632 BV CUISINE INC 8 October 2018 OR No. 4634 BV CUISINE INC 21 OR No. 4633 BV CUISINE INC November 2018 OR No. CIGNAL TV INC 21 5524332 CIGNAL TV INC CIGNAL TV INC November OR No. 2018 5524331 21 OR No. November 5525246 2018 21 November 2018 21 November 2018 8 N o v e m b er 2018 8 November 2018 23 November 2018

DECISION CTA CASE NO. 10413 "P-27 -412" 21 OR No. Delta Neosolutions Inc 89,195.17 10,703.42 "P-27 -418" November 15078 33,000.00 3,960.00 "P-27 -434" 362,027.17 "P-27 -435" 2018 OR No. DSV Air and Sea Inc 380,153 .17 43,443.26 "P-27 -436" 22 0006743 362,302.08 45,618.38 "P-27-437" 24,107.17 43,476 .2 5 "P-27 -439" November OR No. GLOBE TELECOM 12,000.00 "P-27 -441" 2018 3708796 INC 87,000.00 ' "P-27 -442" OR No. GLOBE TELECOM 87,000.00 "P-27 -443" 31 October 3717598 INC 2,892 .86 "P-27 -443" 2018 3,500.00 1,440.00 "P-27-444" 22 OR No. GLOBE TELECOM 3,300.00 10,440.00 "P-27 -444" 3730178 INC 46,038.75 10,440.00 "P-27 -444" November 9,170.83 "P-27-444" 2018 OR No. GM Joe Logistics 9,370.75 420 .00 "P-27 -444" 26 0000083 Corp. 18,341.75 396.00 "P-27 -445" 19,141.33 5,524.65 December OR No. 5023 INFO VISION 49,788.00 1,100.50 2018 RESEARCH 1,124.49 OR No. SYSTEMS INC 2,201 .01 13 929781 INNOVE 2,296.96 COMMUNICATION 5,974.56 Noven1.ber OR No. S INC 2018 929780 INNOVE r' 23 COMMUNICATION OR No. S INC November 0037611 INTELLICARE 2018 22 OR No. INTELLICARE 0037611 November 2018 OR No. INTELLICARE 22 0036875 November OR No. I N TE LLICA RE 2018 0036875 28 OR No. INTELLICARE December 0036875 2018 28 OR No. INTELLICARE 0036875 December 2018 OR No. INTELLICARE 13 0036875 December OR No. INTELLICARE 2018 0037612 13 December 2018 13 December 2018 13 December 2018 13 December 2018 28 December 2018

DECISION CTA CASE NO. 10413 " P -27 -445" 28 OR No. INTELLICARE 6,400.00 768.00 " P-27 -445" December 0037612 300.00 36.00 "P-27-445" INTELLICARE 216.00 " P -27 -445" 2018 OR No. 1,800.00 36.00 "P-27-447" 28 0037612 INTELLICARE 300.00 "P-27-448" 2,040.00 "P-27 -449" December OR No. INTELLICARE 17,000.00 2,040.00 "P-27-475" 2018 0037612 17,000.00 9,000.00 " P -27 -479" 28 JEONSOFT 75,000.00 2,812.50 " P -27 -480" OR No. CORPORATION 23,437.50 "P-27 -480" December 0037612 120.00 "P-27-480" 2018 JEONSOFT 1,000.00 44.67 " P -27 -480" 28 OR No. 2805 372.25 11,720.47 "P-27 -480" CORPORATION 1,450.31 "P-27 -480" December OR No. 2806 97,670.58 1,251.20 "P-27 -486" 2018 JOBSTREET 12,085.92 12,959.22 "P-27 -486" 8 OR No. 10,426.67 29.78 "P-27-486" 21122893 Mr JA Printing and 107,993.50 576 .00 November Giveaways 288.00 2018 OR No. 0321 248 .17 528.00 NORTHSTAR 4,800.00 9 OR No. INTERNATIONAL 2,400.00 r 0035530 TRAVEL INC 4,400.00 November OLIVE 2018 OR No. MAINTENANCE 20 0007687 SERVICES INC OLIVE November OR No. MAINTENANCE 2018 0007687 SERVICES INC 26 OLIVE OR No. MAINTENANCE November 0007687 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 26 October 0007687 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 23 0007687 SERVICES INC November OLIVE OR No. MAINTENANCE 2018 0007687 SERVICES INC 23 Philscan Travel and OR No. Tours Inc November 0159262 Philscan Travel and 2018 OR No. Tours Inc 23 0159262 Philscan Travel and OR No. Tours Inc November 0159262 2018 23 November 2018 23 November 2018 23 November 2018 26 October 2018 26 October 2018 26 October 2018

DECISION CfA CASE NO . 10413 "P-27-486" 26 October OR No. Philscan Travel and 2,400.00 288 .00 "P-27 -486" 2018 0159262 Tours Inc 2,400.00 288.00 "P-27-487" OR No. Philscan Travel and 2,400 .00 288.00 "P-27 -488" 26 October 0159262 Tours Inc 2,400.00 288.00 "P-27 -488" 2018 OR No. Philscan Travel and 2,400.00 288.00 "P-27 -488" 0159261 Tours Inc 4,800.00 576.00 "P-27-488" 26 October OR No. Philscan Travel and 2,400.00 288.00 "P-27-489" 2018 0159366 Tours Inc 2,400.00 288.00 "P-27 -490" OR No. Philscan Travel and 2,400.00 288 .00 31 October 0159366 Tours Inc "P-27 -491" 2018 OR No. Philscan Travel and 2,400.00 288.00 0159366 Tours Inc "P-27 -492" 31 October OR No. Philscan Travel and 2,400.00 288 .00 2018 0159366 Tours Inc "P-27 -493" OR No. Philscan Travel and 5,400.00 648 .00 "P-27-494" 31 October Tours Inc 2,400.00 288.00 2018 159558 "P-27-495" 2,400.00 288 .00 31 October OR No. Philscan Travel and "P-27 -496" 2018 0164823 Tours Inc 2,400.00 288.00 16 "P-27 -498" OR No. Philscan Travel and 9,500.00 1,140.00 "P-27 -499" Novernber 0164825 Tours Inc 9,500.00 1,140.00 2018 "P-27 -500" 22 OR No. Philscan Travel and 19,000.00 2,280.00 0164824 Tours Inc "P-27 -509" November 2,933.08 351.9 7 2018 OR No. Philscan Travel and "P-27-511" 22 0163090 Tours Inc 189,370.00 22,724.40 "P-27 -524" OR No. Philscan Travel and 2,333 .17 279 .98 November 0164202 Tours Inc 2018 r 22 OR No. Philscan Travel and 0165038 Tours Inc November 2018 OR No. Philscan Travel and 0164875 Tours Inc 12 October 2018 OR No. PUNONGBAYAN 9 0174810 ANDARAULLO OR No. PUNONGBAYAN November 0174972 AND ARAULLO 2018 28 OR No. PUNONGBAYAN 0176163 ANDARAULLO November 2018 OR No. SAND RPIZZA 23 0000803 November OR No. SGVANDCO 2018 MK00104072 TERIYAKI BOY 26 October OR No. GROUP INC 2018 0000219 26 November 2018 11 December 2018 8 November 2018 12 October 2018 29 October 2018

DECISIO N CTA CASE NO. 10413 "P-27 -525" 14 OR No. TERIYAKI BOY 81.58 9".79 "P-27 -525" November 0000379 GROUP INC "P-27 -525" "P-27 -525" 2018 OR No. TERIYAKI BOY 81.58 9.79 : "P-27 -525" 14 0000379 GROUP INC "P-27 -525" "P-27 -525" November OR No. TERIYAKI BOY 81.58 9.79 "P-27 -525" 2018 0000379 GROUP INC "P-27 -525" 14 "P-27-526" OR No. TERIYAKI BOY 163.17 19.58 "P-27 -530" November 0000379 GROUP INC "P-27-530" 2018 "P-27-531" 14 OR No. TERIYAKI BOY 81.67 9.80 "P-27 -531" 0000379 GROUP INC "P-27-531" November "P-27 -532" 2018 OR No. TERIYAKI BOY 163.17 19.58 "P-27 -532" 14 0000379 GROUP INC "P-27 -532" November OR No. TERIYAKI BOY 81.58 9.79 2018 0000379 GROUP INC 14 OR No. TERIYAKI BOY 244.75 29.37 November 0000379 GROUP INC 2018 14 OR No. TERIYAKI BOY 81 .58 9.79 0000379 GROUP INC November 2018 OR No. TERIYAKI BOY 1,681.25 201.75 14 0000217 GROUP INC 155,724.67 18,686.96 OR No. 2529 TESORO ALEGRE 5,366,438.08 643,972.57 November INC 738,057.92 88,566 .95 2018 OR No. 2529 TESORO ALEGRE 14 INC OR No. 2547 TESORO ALEGRE November INC 2018 OR No. 2547 TESORO ALEGRE 155,724.67 18,686.96 30 October INC 2018 OR No. 2547 TESORO ALEGRE 5,366,438.08 643,972.57 24 October INC 2018 OR No. 2587 TESORO ALEGRE 811,736 .75 97,408.41 24 October INC 2018 12 OR No. 2587 TESORO ALEGRE 155,724.67 18,686.96 INC Novernber 2018 O R No. 2587 TESORO ALEGRE 82,839.92 9,940.79 12 INC r November 2018 12 November 2018 6 December 2018 6 December 2018 6 December 2018

DECISION CTA CASE NO. 10413 "P-27 -532" 6 OR No. 2587 TESORO ALEGRE 5,366,438.08 643,972.57 "P-27 -533" December INC 1,814.75 883 .92 217.77 " P- 27 -54 2" 2018 OR No. THE FORT CAFE 18 October 13695 AND CATERING I "P-27 -546" SERVICES I 2018 OR No. CORPORATION "P-27 -550" 0008581 THE REAL 106.07 29/ 10/201 AMERICAN "P-27 -551" 8 OR No. DOUGHNUT 2,049.08 245.89 "P-27 -551" 0008681 COMPANY INC "P-27-5 52" 20 THE REAL 620 .50 74.46 "P-27-552" November OR No. AMERICAN "P-27 -553" 0008672 DOUGHNUT 31,090.83 3,730.90 " P -27 -553" 2018 COMPANY INC 29,147 .67 3,497.72 "P-27 -554" OR No. THE REAL "P-27 -554" 19 14518 AMERICAN " P -27 -554" OR No. DOUGHNUT "P-27 -559" November 14518 COMPANY INC "P-27 -559" 2018 Valium Security Services Corp. 8 November Valium Security Services Corp. 2018 8 OR No. Valiwn Security 29,147.67 3,497.72 14543 Services Corp. November 2018 OR No. Valium Security 29,147.67 3,497.72 26 14543 Services Corp. November OR No. Valium Security 1,155.08 138.61 2018 14576 Services Corp. 26 OR No. Valium Security 31,090.83 3,730.90 November 14576 Services Corp. 2018 18 OR No. Valium Security 29,147.67 3,497.72 14657 Services Corp. December 2018 OR No. Valium Security 582.83 69.94 18 14657 Services Corp. 29,147.67 3,497 .72 December OR No. Valium Security 2018 14657 Services Corp. 28 OR No. 2538 TESORO ALEGRE 4,766,630.25 571,995.63 December INC 2018 28 OR No. 2538 TESORO ALEGRE 1,753,715.17 210,445.82 INC December 2018 28 December 2018 7 November 2018 7 November 2018

DECISI ON CTA CASE NO. 104 13 "P-27 -560" 28 OR No. INTELLICARE 197,265.00 23,671.80 "P-27 -560" December 0037620 INTELLICARE 88,817.00 10,658.04 "P-27 -560" INTELLICARE 49,364.00 "P-27 -560" 2018 OR No. INTELLICARE 5,923.68 "P-27-560" 28 0037620 INTELLICARE 118,359 .00 14,203.08 INTELLICARE 115,837.00 13,900.44 "P-27-560" December OR No. INTELLICARE 2018 0037620 INTELLICARE 37,021.00 4,442.52 "P-27 -560" 28 INTELLICARE "P-27 -560" OR No. INTELLICARE 78,906.00 9,468.72 "P-27 -560" December 0037620 INTELLICARE 56,641.00 6,796 .92 "P-27 -560" 2018 INTELLICARE 39,453.00 4,734.36 "P-27 -560" 28 OR No. INTELLICARE 39,453 .00 4,734.36 " P -27-560" 0037620 INTELLICARE 49,364.00 5,923 .68 " P -27 -560" December INTELLICARE 98,728.00 11,847.36 "P-27 -560" 2018 OR No. INTELLICARE 128,270.00 15,392.40 "P-27 -560" 28 0037620 INTELLICARE 118,359.00 14,203 .08 "P-27 -560" 27,068.33 3,248.20 "P-27 -560" December OR No. 1,082.73 2018 0037620 9,022.75 3,309.5 7 27,579.75 28 OR No. r 0037620 December 2018 OR No. 28 0037620 December OR No. 2018 0037620 28 OR No. December 0037620 2018 28 OR No. 0037620 December 2018 OR No. 28 0037620 December OR No. 2018 0037620 28 OR No. December 0037620 2018 28 OR No. 0037620 December 2018 OR No. 28 0037620 December 2018 28 December 2018 28 December 2018 28 December 2018 28 December 2018

DECISION CTA CASE NO . 104 13 "P-27 -560" 28 OR No. INTELLICARE 8,464.50 1,015.74 "P-27 -560" December 0037620 INTELLICARE 9,022.75 1,082.73 "P-27 -560" INTELLICARE 13,789.92 1,654.79 "P-27 -560" 2018 OR No. INTELLICARE 9,022 .75 1,082.73 "P-27 -560" 28 0037620 INTELLICARE 19,424.92 2,330.99 "P-27 -560" December OR No. INTELLICARE 19,424.92 2,330 .99 2018 0037620 "P-27 -560" 28 INTELLICARE 43,031.58 5,163.79 "P-27 -560" OR No. INTELLICARE 18,768.08 2,252.17 "P-27-560" December 0037620 INTELLICARE 15,668.00 1,880.16 "P-27 -560" 2018 INTELLICARE 12,851.17 1,542.14 "P-27 -560" 28 OR No. INTELLICARE 19,424.92 2,330.99 "P-27 -560" 0037620 INTELLICARE 1,126.08 "P-27 -560" December INTELLICARE 9,384.00 1,721.27 "P-27 -560" 2018 OR No. INTELLICARE 14,343.92 2,330.98 "P-27-560" 28 INTELLICARE 19,424.83 "P-27 -560" 0037620 INTELLICARE 163.51 " P -27 -560" December INTELLICARE 1,362.58 167.11 2018 OR No. 1,392. 58 163 .51 0037620 1,362.58 28 r OR No. December 0037620 2018 28 OR No. 0037620 December 2018 OR No. 28 0037620 December OR No. 2018 0037620 28 OR No. December 0037620 2018 28 OR No. 0037620 December 2018 OR No. 28 0037620 December OR No. 2018 0037620 28 OR No. December 0037620 2018 28 OR No. 0037620 December 2018 28 December 2018 28 December 2018 28 December 2018 28 December 2018

DECISION CTA CASE NO . 10413 "P-27 -560" 28 OR No. I N T E LLICA R E 1,362.58 163.51 "P-27 -560" December 0037620 INTELLICARE 2,845.33 341.44 "P-27 -560" INTELLICARE 17,766.33 2,131.96 "P-27 -560" 2018 OR No. INTELLICARE 43,972.92 5,276 .75 "P-27 -560" 28 0037620 INTELLICARE 21,066 .92 2,528.03 INTELLICARE "P-27 -560" December OR No. INTELLICARE 21,526.75 2,583.21 2018 0037620 INTELLICARE "P-27-560" 28 INTELLICARE 10,533.50 1,264.02 "P-27-560" OR No. INTELLICARE 21,066.92 2,528.03 "P-27 -560" December 0037620 INTELLICARE 41,093 .50 4,931.22 "P-27 -560" 2018 INTELLICARE "P-27-561" 28 OR No. INTELLICARE 4,490.00 538.80 " P -27 -561" 0037620 INTELLICARE 62,312.00 7,477.44 "P-27-561" December INTELLICARE 31,479.08 3,777.49 "P-27 -561" 2018 OR No. INTELLICARE 682,181.00 81,861.72 "P-27-561" 28 0037620 INTELLICARE 195,733.00 23,487.96 "P-27-561" 238,230.00 28,587.60 "P-27 -561" December OR No. 15,578.00 1,869.36 2018 0037620 23,974.00 2,876.88 28 OR No. r 0037620 December 2018 OR No. 28 0037620 December OR No. 2018 0037620 28 OR No. December 0037613 2018 OR No. 28 0037613 December OR No. 2018 0037613 28 OR No. December 0037613 2018 OR No. 28/12/ 201 0037613 8 28 OR No. 0037613 December 2018 OR No. 28 0037613 December 2018 28 December 2018 28 Decemb er 2018 28 December 2018 28 December 2018

DECISION CTA CASE NO. 104 13 "P-27 -561" 28 OR No. INTELLICARE 50,648.00 6,077.76 " P -27 -561" December 0037613 INTELLICARE 27,031.00 3,243.72 "P-27 -561" INTELLICARE 183,100.00 21,972.00 "P-27 -561" 2018 OR No. INTELLICARE 58,721.00 7,046.52 "P-27 -561" 28 0037613 INTELLICARE 23,440.00 2,812.80 "P-27 -561" 120,788.00 14,494.56 "P-27-561" December OR No. INTELLICARE 15,578.00 1,869.36 "P-27 -561" 2018 0037613 31,156.00 3,738.72 "P-27 -561" 28 INTELLICARE 46,734.00 5,608.08 " P-27-561" OR No. INTELLICARE 19,492.00 2,339.04 "P-27 -561" December 0037613 INTELLICARE 62,312.00 7,477.44 "P-27 -561" 2018 INTELLICARE 374,106.00 44,892.72 "P-27 -561" 28 OR No. INTELLICARE 71,031.00 8,523.72 "P-27-561" 0037613 INTELLICARE 80,696.00 9,683 .52 "P-27 -561" December INTELLICARE 191,173.00 22,940.76 "P-27 -561" 2018 OR No. INTELLICARE 345,060.00 41,407.20 "P-27-561" 28 INTELLICARE 258,858.00 31,062.96 0037613 INTELLICARE December INTELLICARE - - -- - r 2018 OR No. 28 0037613 Decem.ber OR No. 2018 0037613 28 OR No. December 0037613 2018 OR No. 28 0037613 December OR No. 2018 0037613 28 OR No. December 0037613 2018 28 OR No. 0037613 December 2018 OR No. 28 0037613 December OR No. 2018 0037613 28 OR No. December 0037613 2018 28 OR No. 0037613 December 2018 28 December 2018 28 December 2018 28 December 2018 28 December 2018

DECISION CTA CASE NO. 10413 "P-27 -561" 28 OR No. INTELLICARE 400,975.00 48,117.00 "P-27 -561" December 0037613 INTELLICARE 307,691.00 36,922.92 "P-27 -561" INTELLICARE 11,552.88 "P-27 -561" 2018 OR No. INTELLICARE 96,274.00 44,928.12 "P-27 -561" 28 0037613 INTELLICARE 374,401.00 INTELLICARE 6,116.52 "P-27 -561" December OR No. INTELLICARE 50,971.00 2018 0037613 INTELLICARE 20,679.24 "P-27-561" 28 INTELLICARE 172,327.00 "P-27 -561" OR No. INTELLICARE 3,738.72 "P-27 -561" December 0037613 INTELLICARE 31,156.00 17,414.28 "P-27-561" 2018 INTELLICARE 145,119.00 31,361.64 "P-27-561" 28 OR No. INTELLICARE 261,347.00 "P-27 -561" 0037613 INTELLICARE 1,869.36 "P-27-561" December INTELLICARE 15,578.00 17,941.68 "P-27-56 1" 2018 OR No. INTELLICARE 149,514.00 "P-27-561" 28 0037613 INTELLICARE 9,683.52 "P-27 -561" 80,696.00 7,516.20 "P-27 -561" December OR No. 62,635.00 2,206.08 2018 0037613 18,384.00 1,869.36 15,578.00 6,615.60 28 OR No. 55,130.00 19,415. 88 0037613 161,799 .00 December i 2018 OR No. 28 0037613 December OR No. 2018 0037613 28 OR No. December 0037613 2018 28 OR No. 0037613 December 2018 OR No. 28 0037613 December OR No. 2018 0037613 28 OR No. December 0037613 2018 28 OR No. 0037613 December 2018 OR No. 28 0037613 December 20 18 28 December 2018 28 December 2018 28 December 2018 28 December 2018

DECISI ON CTA CASE NO . 10413 "P-27 -56 1 " 28 OR No. INTELLICARE 31,156.00 3,738.72 "P-27 -562" December 0037613 INTELLICARE 117,197.00 14,063.64 "P-27 -562" INTELLICARE "P-27 -562" 2018 OR No. INTELLICARE 189,832.00 22,779.84 "P-27 -562" 28 0037610 INTELLICARE 62 ,3 12 .00 7,477.44 "P-27 -562" December OR No. INTELLICARE 274,436 .00 32,932.32 2018 0037610 "P-27 -562" 28 INTELLICARE 176,163.00 21,139 .56 " P-2 7-562" OR No. INTELLICARE "P-27-562" December 0037610 INTELLICARE 46,734.00 5,608.08 "P-27 -562" 2018 INTELLICARE "P-27 -562" 28 OR No. INTELLICARE 31,156.00 3,738.72 "P-27 -562" 0037610 INTELLICARE "P-27 -562" December INTELLICARE 18,384.00 2,206 .08 "P-27 -562" 2018 OR N o. INTELLICARE "P-27 -562" 28 INTELLICARE 93,468.00 11,216.16 "P-27 -562" 0037610 INTELLICARE "P-27 -562" December INTELLICARE 853,512.00 102,421.44 2018 OR No. 0037610 46,734.00 5,608.08 28 OR No. 15,578.00 1,869 .36 December 0037610 2018 62,312.00 7,477.44 28 OR No. 0037610 39,074.00 4,688.88 December 2018 OR No. 187 ,582 .00 22,509.84 28 0037610 62,312.00 7,477 .44 December OR No. 2018 0037610 r 28 OR No. December 0037610 2018 28 OR No. 0037610 December 2018 OR No. 28 0037610 December OR No. 2018 0037610 28 OR No. December 0037610 2018 28 OR No. 0037610 December 2018 28 December 2018 28 December 2018 28 December 2018 28 December 2018

DECISION CfA CASE NO. 104 13 "P-27 -562" 28 OR No. INTELLICARE 620,367.25 74,444.07 "P-27 -562" December 0037610 INTELLICARE "P-27-562" INTELLICARE 288,388 .00 34,606.56 "P-27 -562" 2018 OR No. INTELLICARE "P-27 -562" 28 0037610 INTELLICARE 93,468 .00 11,216.16 "P-27 -562" INTELLICARE "P-27 -562" December OR No. INTELLICARE 384,709.00 46,165.08 "P-27 -562" 20 18 0037610 INTELLICARE "P-27 -562" 28 INTELLICARE 440,186 .00 52,822 .32 "P-27 -562" OR No. INTELLICARE "P-27 -562" December 0037610 INTELLICARE 722,995.42 86,759.45 " P -27 -562" 2018 INTELLICARE "P-27-562" 28 OR No. INTELLICARE 812,669.00 97,520.28 "P-27 -562" 0037610 INTELLICARE "P-27 -562" December INTELLICARE 257,666.00 30,919.92 " P -27 -562" 20 18 OR No. INTELLICARE "P-27 -562" 28 0037610 INTELLICARE 1,554,331.00 186,519 .72 December OR No. 288,310.00 34,597.20 2018 0037610 28 353,655.00 42,438.60 OR No. December 0037610 676,541.00 81 ,1 84.92 2018 28 OR No. 851,993.00 102,239.16 00376 10 December 109,046.00 13,085.52 2018 OR No. 28 0037610 77,968.00 9,356 .16 December OR No. 15,578.00 1,869.36 2018 0037610 28 428,541.00 51 ,424.92 OR No. December 0037610 2018 28 OR No. 0037610 December 2018 OR No. 28 0037610 December OR No. 2018 0037610 28 OR No. D ecember 0037610 2018 28 OR No. 0037610 December 2018 28 December 2018 28 December 2018 28 December 20 18 28 December 20 18

DECISION CTA CASE NO. 10413 "P-27 -562" 28 OR No. INTELLICARE 27,259.00 3,271 .08 "P-27 -562" December 0037610 494,612.83 59,353.54 "P-27 -562" 148,620.00 17,834.40 "P-27 -562" 2018 OR No. INTELLICARE 128,638.00 15,436.56 "P-27 -562" 28 0037610 215,616.00 25,873 .92 "P-27 -562" December OR No. INTELLICARE 456,519.00 54,782.28 2018 0037610 "P-27 -562" 28 47,948.00 5,753 .76 "P-27 -562" OR No. INTELLICARE 10 1,296 .00 12,155.52 "P-27 -562" December 0037610 42,609 .00 5,113.08 "P-28- 100" 2018 "P-28-1 01" 28 OR No. INTELLICARE 4,400.00 528.00 " P -28- 102" 0037610 2,200 .00 264.00 " P -28- 103" D ecember 1,320.00 158.40 "P-28-1 04" 2018 OR No. INTELLICARE 2,200.00 264.00 "P-28-115" 28 2,200.00 264.00 0037610 1,885.75 226.29 "P-28-116" December 2018 OR No. INTELLICARE "P-28-121" 0037610 " P- 28- 124" 28 "P-28-125" OR No. INTELLICARE December 0037610 2018 28 OR No. INTELLICARE 0037610 December 2018 OR No. RAJAH TRAVEL 303.58 36.43 28 127495 CORPORATION OR No. RAJAH TRAVEL 24,688.58 2,962.63 D ecember 123183 CORPORATION 745.50 89.46 2018 OR No. RAJAH TRAVEL 520.17 28 125601 CORPORATION 4,334.7 5 OR No. RAJAH TRAVEL December 128931 CORPORATION 2018 OR No. RAJAH TRAVEL 128930 C O RP O R A T I O N 8 March OR No. THE REAL 2018 0007434 AMERICAN DOUGHNUT 25 January OR No. COMPANY INC 2018 0007447 THE REAL AMERICAN 21 February O R No. 2059 DOUGHNUT 20 18 COMPANY INC OR No. ADD BELL 26 March 17181 TECHNICAL 2018 OR No. 0026 SERVICES INC BV CUISINE INC 26 March 2018 BV CUISINE INC 22 March 2018 26 March 2018 22 November 2018 14 June 2019 26June 2018

DECI SI ON CTA CASE NO. 104 13 "P-28-131" 5 October OR No. 3645 Continental Rental and 3,200.00 384.00 "P-28-131" 2018 Tours Inc 8,400 .00 1,008.00 "P-28-131" OR No. 3645 Continental Rental and 6,350.00 "P-28-131" 5 October Tours Inc 6,350.00 762.00 "P-28-134" 2018 OR No. 3645 Continental Rental and 3,250.00 762.00 Tours Inc 390.00 "P-28-136" 5 October OR No. 3645 Continental Rental and 25,000.00 "P-28-141" 2018 Tours Inc 365,017.42 3,000.00 OR No. EMPIRE 43,802 .09 "P-28-144" 5 October 001637 AUTOMATION 6,000.00 2018 PHILIPPINES INC 720.00 "P-28-145" 15 OR No. Fujitsu Philippines Inc. 49,807 .08 "P-28-146" 1400004650 49,158.83 5,976 .85 "P-28-146" November GLOBE TELECOM 5,899.06 "P-28-146" 2016 OR No. INC 2,016.92 "P-28-146" 3696438 1,346 .50 242.03 "P-28-146" 31 October 2,017 .08 161.58 "P-28-146" 2018 OR No. 3887 INFO VISION 1,346.50 242 .05 "P-28-146" 1 RESEARCH 1,346.50 161.58 "P-28-146" OR No. SYSTEMS INC 1,346.50 161.58 "P-28-146" September 0028768 INTELLICARE 1,346.50 161.58 "P-28-146" OR No. INTELLICARE 1,346.50 161.58 "P-28-146" 2018 0033112 INTELLICARE 4,039.42 161.58 "P-28-146" OR No. INTELLICARE 1,346.50 484.73 "P-28-146" 5 October 0033112 INTELLICARE 2,692.92 161.58 "P-28-146" 2018 OR No. INTELLICARE 6,051.17 323.15 "P-28-146" 0033112 INTELLICARE 2,692.92 726.14 2 August OR No. INTELLICARE 1,346.50 323.15 2018 0033112 INTELLICARE 161.5 8 OR No. INTELLICARE 9 October 0033112 INTELLICARE ( 2018 OR No. INTELLICARE 0033112 INTELLICARE 9 October OR No. INTELLICARE 2018 0033112 INTELLICARE OR No. INTELLICARE 9 October 0033112 2018 OR No. 0033112 9 October OR No. 2018 0033112 OR No. 9 October 0033112 2018 OR No. 0033112 9 October OR No. 2018 0033112 OR No. 9 October 0033112 2018 OR No. 0033112 9 October 2018 9 October 2018 9 October 2018 9 October 2018 9 October 2018 9 October 2018 9 October 2018 9 October 2018

DECISION CTA CASE NO. 10413 "P-28-146" 9 October OR No. INTELLICARE 1,908.50 229 .02 "P-28-146" 2018 0033112 INTELLICARE 1,346.50 161.58 "P-28-146" OR No. INTELLICARE 6,051.25 726.15 "P-28-14 7" 9 October 0033112 INTELLICARE 47,252 .7 5 5,670.33 "P-28-148" 2018 OR No. 4,607.17 552.86 "P-28-149" 0033112 22,504.00 2,700.48 "P-28-149" 9 October OR No. 16,650.00 1,998.00 "P-28-149" 2018 0036874 16,900.00 2,028.00 "P-28-149" 13 5,190.00 622.80 "P-28-149" OR No. IRENEO V 30,943.00 3,713.16 "P-28-156" December 0003230 ALONZO 3,382.17 405.86 2018 RESTAURANT "P-28-157" OR No. 4795 JAVIER PROJECT 14,375.00 1,725.00 "P-28-159" 8 May 2018 MANAGERS INC 2,000.00 240.00 OR No. 4795 JAVIER PROJECT "P-28-160" 26 October 60,261.17 7,231.34 2018 OR No. 4795 MANAGERS INC "P-28-160" 9,749.92 1,169.99 "P-28-160" 26 October OR No. 4795 JAVIER PROJECT "P-28-160" MANAGERS INC 97,670.58 11,720.47 "P-28-160" 2018 OR No. 4795 JAVIER PROJECT 11,228.67 1,347.44 MANAGERS INC 14.89 "P-28-160" 26 October OR No. JAVIER PROJECT 124.08 2018 00610 :MANAGERS INC 12,501.84 "P-28-161" LUKFOO 104,182.00 11,396. 88 26 October OR No. 0310 INTERNATIONAL ~- 2018 CUISINE INC 94,974.00 r OR No. Mr JA Printing and 26 October 28604 Giveaways 2018 OFFICESHOPPE OR No. AND SERVICES 30 June 0007643 CORPORATION 2018 OLIVE OR No. MAINTENANCE 5 October 0007643 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 7 January 0007643 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 5 October 0007643 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 5 October 0007643 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 5 October 0007643 SERVICES INC 2018 OLIVE OR No. MAINTENANCE 5 October 0007644 SERVICES INC 2018 OLIVE MAINTENANCE 5 October SERVICES INC 2018 5 October 2018 5 October 2018

DECISION CTA CASE NO. 10413 "P-28-161" 5 October OR No. OLIVE 10,426.67 1,251.20 "P-28-161" 2018 0007644 MAINTENANCE "P-28-163" SERVICES INC 97,670 .58 11,720.47 "P-28-164" 5 October OR No. OLIVE "P-28-165" 2018 0007644 MAINTENANCE 1,500.00 180.00 SERVICES INC 4,800.00 576.00 "P-28-165" 5 October OR No. Philscan Travel and 7,589.25 910.71 2018 0158970 Tours Inc "P-28-165" OR No. Philscan Travel and 7,589.25 910 .71 5 October 0158969 Tours Inc "P-28-178" 2018 OR No. PROPERTY 7,589.25 910.71 "P-28-179" MAINTENANCE 1 October 09427 AND GARDENS 770,901.42 92,508 .17 "P-28-180" 2018 INC 55 1.25 66.15 OR No. PROPERTY "P-28-182" 1 October 1,430.00 171.60 "P-28-182" 09427 MAINTENANCE "P-28-182" 2018 22,626.42 2,715.17 "P-28-182" OR No. AND GARDENS 10,493 .00 1,259.16 "P-28-183" 1 October 09427 INC 11,597 .67 1,391.72 "P-28- 184" 2018 PROPERTY "P-28-187" OR No. 2529 MAINTENANCE 7,374.00 884.88 "P-28-188" 24 October AND GARDENS 4,455.33 534.64 "P-28-189" 2018 OR No. INC 3,563.42 427.61 0007907 TESORO ALEGRE 19 June INC 723.17 86.78 2018 OR No. THE REAL 0007928 AMERICAN 723 .17 86 .78 21June DOUGHNUT 2018 OR No. COMPANY INC 445. 50 53.46 0121269 THE REAL 25 October OR No. AMERICAN 2018 0121269 DOUGHNUT OR No. COMPANY INC 25 October 0121269 UBIX 2018 OR No. 0121269 UBIX 25 October OR No. 2018 UBIX 09279 25 October OR No. UBIX 2018 09276 OR No. 2669 YELLOW CAB 21June FOOD CORP 2018 YELLOW CAB FOOD CORP 18June BV CUISINE INC 2018 18 OR No. 2706 BV CUISINE INC September OR No. COFFEE TABLE 2018 0000601 INC 25 September 2018 29 August 2018

DECISION CTA CASE NO. 10413 "P-28-195" 9 October OR No. INTELLICARE -1,060.25 -127.23 "P-28-195" 2018 0033112 -1,060.33 -127.24 "P-28-195" OR No. INTELLICARE 113.60 "P-28-195" 9 October 0033112 946.67 113.60 "P-28- 195" 2018 OR No. INTELLICARE 946.67 -254.47 "P-28-195" 0033112 -2,120 .58 -127.23 "P-28-195" 9 October OR No. INTELLICARE -1,060.25 "P-28-195" 2018 0033112 300.00 36.00 "P-28-19 5" OR No. INTELLICARE 979.58 117 .55 "P-28-195" 9 October 0033112 979.58 117.55 "P-28-195" 2018 OR No. INTELLICARE -548 .58 -65.83 "P-28-195" 0033112 -548.58 -65.83 "P-28-195" 9 October OR No. INTELLICARE 489.75 "P-28-195" 2018 0033112 489.83 58.77 "P-28-195" OR No. INTELLICARE 946.67 58.78 "P-28-204" 9 October 1,893.33 113.60 2018 0033112 INTELLICARE 750.00 227 .20 "P-28-205" 90 .00 9 October OR No. INTELLICARE "P-28-206" 2018 0033112 442.00 53.04 OR No. INTELLICARE "P-28-207" 9 October 0033112 1,160.75 139.29 OR No. INTELLICARE "P-28-52" 2018 0033112 3,964.42 475.73 OR No. INTELLICARE 24,599.92 "P-28-53" 9 October 0033112 2,951.99 "P-28-54" 2018 OR No. INTELLICARE 1,799.08 0033112 1,397.33 215.89 9 October OR No. INTELLICARE 167 .68 2018 0033112 OR No. THE REAL . 9 October 0033112 AMERICAN 2018 OR No. DOUGHNUT 0008304 COMPANY INC 9 October THE REAL 2018 OR No. AMERICAN 0008272 DOUGHNUT 9 October COMPANY INC 2018 OR No. THE REAL 0008003 AMERICAN 9 October DOUGHNUT 2018 OR No. 4278 COMPANY INC WILD FLOURE 9 October OR No. 1589 BAKERY CAFE 2018 CORP 5 OR No. ADD BELL 3734969 TECHNICAL September OR No. SERVICES INC 2018 3734968 CIGNAL TV INC 30 August CIGNAL TV INC 2018 4 July 2018 21 September 2018 2 May 2018 12 April 2018 12 April 2018

DECISION CTA CASE NO . 10413 "P-28-55" 4 May 2018 OR No. 3607 INFO-VISION 9,000.00 1,080.00 RESEARCH "P-28-56" 6 June 2018 OR No. SYSTEMS, INC. 48,219.25 5,786.31 "P-28-61" 0018154 INTELLICARE 24,097.25 2,89 1.67 2 August OR No. 2004 "P-28-61" 20 18 ADD BELL 22,707 .58 2,724.91 OR No. 2004 TECHNICAL "P-28-61" 2 August SERVICES INC 23,801.58 2,856.19 2018 OR No. 2004 ADD BELL "P-28-61" TECHNICAL 21,761.42 2,611.37 2 August OR No. 2004 SERVICES INC "P-28-64" 2018 ADD BELL 1,397.33 167.68 "P-28-65" OR No. TECHNICAL 1,799 .08 215 .89 2 August 3881436 SERVICES INC 2,156.25 258.75 "P-28-66" OR No. ADD BELL 116,356.00 13,962.72 2018 3881435 TECHNICAL 11 ,497.58 1,379.71 "P-28-67" OR No. SERVICES INC 3,930.00 471.60 "P-28-68" 4 July 2018 0001358 CIGNAL TV INC "P-28-73" OR No. 87,000.00 10,440.00 4 July 2018 CIGNAL TV INC "P-28-7 4" 14569 3,930.00 471.60 5 March OR no. 2634 COFIBUN "P-28-75" 2018 SPECIALS INC 87,000.00 10,440.00 25 July OR No. Delta N eosolutions Inc "P-28-76" 2018 0896747 600.00 72.00 DIVE AND TREK 300.00 36.00 "P-28-77" 11 March OR No. CORP 49,271.00 5,912.52 "P-28-77" 2018 0896749 INNOVE 8,065 .83 967.90 "P-28-78" COMMUNICATION 5,377.25 645 .27 "P-28-79" 4 July 2018 OR No. S INC 4,463.42 535.61 "P-28-79" 0896746 INNOVE "P-28-79" 4 July 2018 COMMUNICATION 1-- OR No. S INC 4 July 2018 0896748 INNOVE COMMUNICATION 4 July 2018 OR No. S INC 0026795 INNOVE 2 July 2018 OR No. COMMUNICATION 0026795 S INC 2July 2018 OR No. INTELLICARE 0026794 2July 2018 OR No. INTELLICARE 0028768 2 August OR No. INTELLICARE 2018 0028768 OR No. INTELLICARE 2 August 0028768 2018 INTELLICARE 2 August INTELLICARE 2018

DECISION CTA CASE NO . 104 13 "P-28-79" 2 August OR No. INTELLICARE 10,640.17 1,276.82 9,265.17 1,111.82 2018 0028768 4,688.75 10,065 .92 562.65 "P-28-79" 2 August OR No. INTELLICARE 4,688.75 1,207.91 . 2,688.58 2018 0028768 2,688.58 562.65 2,231.67 322.63 "P-28-79" 2 August OR No. INTELLICARE 5,777.00 322.63 3,088.42 267.80 2018 0028768 7,377.33 693 .24 7,55 1.83 370.61 "P-28-79" 2 August OR No. INTELLICARE 9,063 .17 885 .28 906.22 2018 0028768 88,459.42 1,087 .58 "P-28-79" 2 August OR No. INTELLICARE 2,400.00 10,615.13 2,400.00 2018 0028768 2,400.00 288.00 2,400.00 288.00 "P-28-79" 2 August OR No. INTELLICARE 2,400.00 288.00 2,400.00 288.00 2018 0028768 2,400.00 288.00 2,400.00 288.00 "P-28-79" 2 August OR No. INTELLICARE 2,400 .00 288 .00 288.00 2018 0028768 288.00 "P-28-79" 2 August OR No. INTELLICARE 2018 0028768 "P-28-79" 2 August OR No. INTELLICARE 2018 0028768 "P-28-79" 2 August OR No. INTELLICARE 2018 0028768 "P-28-79" 2 August OR No. INTELLICARE 2018 0028768 "P-28-79" 2 August OR No. INTELLICARE 2018 0028768 "P-28-92" 5July2018 OR No. OLIVE 0007536 MAINTENANCE SERVICES INC "P-28-93" 5July2018 OR No. OLIVE 0007537 MAINTENANCE SERVICES INC "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 01695 17 Tours, Inc. "P-28-94" 2 July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. "P-28-94" 2July 2018 OR No. Philscan Travel and 0169517 Tours, Inc. 2) Items/goods purchased not enumera ted in th e s upporting Sf --~ r

DECISION CTA CASE NO. 10413 "P-27-128" 26 August SINo. 06099 RUSTAN 42,962.08 5,155.451 2018 COMMERCIAL ! CORPORATION 215.37 307 .23 3) Purchase ofservices s upported by OR butpetitioner's address is not 7.50 indicated thereon 7.50 7.50 "P-27-462" 5 October OR No. MAX S GROUP INC 1,794.75 22.50 7.50 2018 0007200 7.50 15 .00 4) With unreadable details- VAT amount and/or date oftransaction cannot be 7.50 15.00 ascertained 218.00 "P-27-59" 12 August SINo. KAREILA 2,560.25 2018 01272263 IvlANAGEMENT CORPORATION "P-27 -544" 14 OR No. THE REAL 62.50 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-27 -544" 14 OR No. THE REAL 62.50 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-27 -544" 14 OR No. THE REAL 62. 50 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC " P -27 -544" 14 OR No. THE REAL 187. 50 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-27 -544" 14 OR No. THE REAL 62. 50 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-27 -544" 14 OR No. THE REAL 62. 50 November 100012599 AMERICAN 20 18 DOUGHNUT COMPANY INC "P-27 -5 44" 14 OR No. THE REAL 125.00 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-27 -544" 14 OR No. THE REAL 62.50 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-27 -544" 14 OR No. THE REAL 125.00 November 100012599 AMERICAN 2018 DOUGHNUT COMPANY INC "P-28-1 08" 26 February OR No. RUSTANS COFFEE 1,816.67 2018 00000000000 CORP 00299401

DECISION CTA CASE NO. 10413 "P-28-171" 14 June OR No. RUSTAN COFFEE 1,533.33 184.00 2018 00000000000 CORPORATION 00398916 5) Supporting OR does not correspond to the input VAT claim "P-28-13 7" 6 OR No. Fujitsu Philippines Inc. 24,500.00 2,940.00 September 1400004650 2018 Total Php99,100,066.25 Php11,892,007.95 Based on the foregoing, relative to petitioner's compliance with the seventh requisite, out of the Php21,616,914.71 total input VAT claim, only the amount ofPhp3,177,731.70 represents petitioner's valid input VAT, as computed below: Input VAT Claim Php21,616,914.71 Less: Disallowances Php6,547,175.06 Per ICPA report Per this Court's further 11,892,007.95 18,439,183.01 verification Php3,177,731.70 Valid In_put VAT Since petitioner's reported sales were all zero-rated, the substantiated input taxes are entirely attributable thereto. The eighth reqms1te is to the effect that the input taxes claimed are attributable to zero-rated or effectively zero-rated sales. However, where there are both zero-rated or effectively zero-rated sales and taxable or exempt sales, and the input taxes cannot be directly and entirely attributable to any of these sales, the input taxes shall be proportionately allocated on the basis of sales volume. In the present case, there being no reported taxable or exempt sales, but only zero-rated sales/receipts, the entire amount of Php3,177,731.70 properly substantiated input VAT is attributable to the entire reported zero-rated sales/receipts of Php888,563,454.98 for the CY 2018. However, as stated earlier, petitioner was able to properly substantiate only the amount of Php883,293,500.00 out of its total declared zero-rated sales/receipts of Php888,563,454.98. Thus, as regard to petitioner's compliance with the eighth requisite, only the amount ofPhp3,158,884.98 represents its valid input VAT attributable to its valid zero-rated sales/receipts of r Php883,293,500.00, as computed below:

DECISION CTA CASE NO. 10413 Valid Input VAT Php 3,177,731.70 Divided by: Declared Zero-Rated Sales/Receipts 888,563,454.98 Multiplied by: Valid Zero-Rated Sales/Receipts 883,293,500.00 Input VAT Attributable to Valid Zero-Rated Sales/Receipts Php3,158,884. 98 The subject input taxes have not been applied against output taxes during and in the succeeding quarters. As already pointed out, petitioner had no reported output tax for the four (4) quarters of CY 2018 as its reported sales/receipts were all zero-rated sales/receipts.93 Thus, it had no output VAT against which the input VAT claim of Php21,616,914.71 may be applied or credited. Moreover, the amount of Php21,616,914.71 was deducted as (VAT Rifund/TCC claimed" in the 1sr Quarterly VAT Return for CY 2019,94 preventing the carry-over or application of such input taxes in the next taxable quarter/s. Hence, petitioner is deemed to have fulfilled the ninth requisite for the refund/ tax credit of input VAT under Section 112(A) of the NIRC of 1997, as amended. In fine, petitioner has sufficiently proven its entitlement to the refund in the amount of Php3,158,884.98, representing excess and unutilized input VAT attributable to its zero-rated sales for the four (4) quarters of CY 2018. WHEREFORE, in light of the foregoing considerations, the present Petition for Review is PARTIALLY GRANTED. Accordingly, respondent is ORDERED TO REFUND in favor of petitioner the amount of Php3,158,884.98 representing petitioner's excess and unutilized input VAT attributable to its zero-rated sales/receipts for the four (4) quarters of CY 2018. SO ORDERED. ~ . ~ -?~ MA. BELEN M. RINGPIS-LIBAN Associate Justice 93 Id., Exhibits "P-9-2", "P-9-4", "P-9-6" and "P-9-8", pp. 679, 688, 696 and 703, respectively. 94 Id., Line 230, Exhibit "P-10", p. 707.

DECISION CTA CASE NO. 10413 WE CONCUR: C~ (;:FERRER-FLORES Associate Justice ATTESTATION I attest that the conclusions in the above decision were reached in consultation before the case was assigned to the writer of the opinion of the Court. ~. ~"'-- '-' ' - MA. BELEN M. RINGPIS-LIBAN Associate1ustice Chairperson CERTIFICATION Pursuant to Article VIII, Section 13 of the Constitution, and the Division Chairperson's Attes tation, it is hereby certified that the conclusions in the above Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court. Presiding1ustice