COMMISSIONER OF INTERNAL REVENUE v. EXPEDITORS PHILIPPINES, INC.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC COMMISSIONER OF CTA EB NO . 2835 INTERNAL REVENUE, (CTA Case 1 o . 9257) Petitioner, P resent: - ver.ru.r - Ringpis-Liban, Acting EJ., Manahan, Baco r r o -Villena, Modesto-San Pedro, R eyes-F ajard o , C ui-D avid , r errer-Plores, and Angeles, Jl Promulgated: =-t7J.k., EXPEDITORS PHILIPPINES, INC., DEC 17 2025 #2 ~ - R eJpondent. ?r.~ x------------------------------------------------------------------------------------------------x RESOLUTION RINGPIS-LIBAN,� l .'or resolution o f the Court is petitio ner's Motion for Ruomideration (D ed.rion if 27 Febmary 2025) (the " Iotion"), Eled via regis tered mail on March 18, 2025, seeking reconsideration of the Decision promulgated on February 26, 2025, (the "Assailed D ecision"), which denied the P etition for Review for lack o f merit. Respo ndent failed to comment on the ivio tion despite due order fro m the Court. 1 In seeking reconsideration, petitioner reiterates its sole contention that respondent is already estopped from questioning the authority of the revenue officers who conduc ted the audit for taxable year 2009. 1 Records Verification Report dated July 29, 2025.

RESOLUTION CTA EB No. 2835 (CTA Case No. 9257) "\fter cardul evaluation of petitioner's contention v1s-it-v1s the case records, pertinent laws, and jurisprudence, the Court finds the i\Iotion to be without merit. In Sbm1,~1i-!a llllematio11al T-Totel i\!aJIC(~eJJJflll, Ltd.. e/ a!. ?J. Deve!operJ Gro11p o/ Compa11ie.r, 111,:,�' the Supreme Court held that a motion for reconsideration must raise matters that arc substantially plausible to warrant the relief sought, thus: The bulk of the aforementioned grounds is a mere rehash of mm�ants ptcc\�ious arguments. \X:hik DC~C:I is correct in stating that a motion for reconsideration, lw its ,-ery nature, mm� tend to dwell on issues alt-cad,- resoked in the decision sought to be reconsidered and that this should not be an obstacle for a reconsideration, the hard reality is that mm�ant has failed to raise matters substantially plausible or compelling!\� persuasiYc to warrant the desired cause of action. Considering that the grounds presentlY raised haYe been sufficient!\� considered, if not squareh� addressed, in the subject l)ccision, it bchocn-cs rncn-ant to con,-incc the Court that certain findings or conclusions in the Decision arc contrary to law. ,\s it is,' howe,�er, the instant motion docs not raise any new or substantial' legitimate ground or reason to justify the reconsideration sought. SimilarlY, in I !atq L Roqm, .Jr., et. a!. 11. Commissio11 on E!ettiom, repre.re11ted by I-lon. C!wirma11]oJe Melo, et a/., 3 the Supreme Court E11 Bant ruled that when a motion for reconsideration fails to raise matters substantially plausible or compellingly persuasive, it must be denied, thus: Petitioner's abm�c contention, as well as the arguments, citations and premises holding it together, is a rehash of their pre\'ious position articulated in their memorandum in support of their petition. They han' been considered, sc1u:rreh� addressed, and found to be without n1crit in the l)cci::;ion ::-ubjcct hereof. The Court is not inclined to embark on another extended discussion of the same issue again x x x. \\'hile a motion for reconsideration mm� tend to dwell on issues alreach� resokcd in the decision sought to be reconsidered - and this should not he an obstacle for a reconsideration- the hard rcalitv is that petitioners hm�c failed to raise matters substantially plausible or compcllinl<!h' '- pcrsuasi\'C to warrant the desired course of action. The Court finds that petitioner failed to advance any new, substantial, or compelling reason to warrant the modification or reversal of the :\ssailcd r Decision. ' G.R. No. 159938 (Resolution), January 22, 2007. 3 G.R. No. 188456 (Resolution), February 10, 2010.

RESOLUTION CTA EB No. 2835 (CTA Case No. 9257) ACCORDINGLY, petitioner's Motion for Reconsideration (Detision o/27 Febmary 2025) is DENIED for lack of merit. SO ORDERED. 7-- ~-~ MA. BELEN M. RINGPIS-LIBAN Associate Justice lr7:': CW\'CUR: c~-�7-~~ CATHERINE T. MANAHAN .\ssociate Justice "�� � . BACORRO-VILLENA MARIA PEDRO ~ ~ t ~-f=01Wvk MARIAN IVY fl. REYE~-FAJA'RDO .\ssociate Justicc LA~~VID ,\ssociate justice

RESOLUTION CTA EB No. 2835 (CTA Case No. 9257) HENRY jlgGELES c\ssociatc Justice