cta_resolution CTA Case No. EB 2835EB 2835 2025-12-17

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

Want an analysis of this document?

Ask ASG Legal AI to summarize it, compare it with other rulings, or explain how it applies to your situation — it researches from this same library.