COMMISSIONER OF INTERNAL REVENUE v. PROCTER AND GAMBLE ASIA, PTE. LTD.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC COMMISSIONER OF CTA EB NO. 1576 (CTA Case Nos. 7523 & 7556) INTERNAL REVENUE, Present: Petitioner, -versus- Del Rosario, P.J., Castaneda, Jr., Uy, Pabon-Victorino, Mindaro-Grulla, Ringpis-Liban, and Manahan,JJ. PROCTER & GAMBLE ASIA, Promulgated: PTE. LTD., DEC 2-7 2018 Respondent. ~#.9'/t:::l�,._. x--------------------------------------------------------------~-------------------x RESOLUTION CASTANEDA, JR., J.: For resolution is petitioner's September 6, 2018 Motion for Reconsideration, with Comment I Opposition (Re: Respondent's Motion for Reconsideration dated September 6, 20 18) from respondent filed on October 29, 2018. The motion asks the Court to "review, re-evaluate, revisit and take a second look" at the decision that denied the petition and held that the taxpayer's pieces of evidence are not hearsay and have probative value to support the refund claim. A review of the factual and legal bases of the arguments in the motion reveals that these are the very same bases stated in the following pleadings and/or motions: � June 3, 2016 Motion for Partial Reconsideration' which were discussed at length in the November 22, 2016 Resolution ofthe CTA Special First Division.2 L; 1 Division Docket (CTA Case No. 7523), Vol. IV, pp. 3398-3404. 2 Rollo, pp. 52-54.

RESOLUTION CTA EB No. 1576 (CTA Case Nos. 7523 & 7556) Page 2 of3 � December 27, 2016 Petition for Review3 filed with the Court En Bane which were addressed in the July 24, 2018 Decision.4 Accordingly, since the arguments raised by petitioner are mere rehash and repetitions and were already considered and thoroughly threshed out, the Motion for Reconsideration deserves scant consideration. WHEREFORE, premises considered, petitioner's Motion for Reconsideration is hereby DENIED for lack of merit. SO ORDERED. ~"c.~-~, 2. JtfANITO C. CASTANEDX', JR. Associate Justice WE CONCUR: E~P.UY Associate Justice ABON-VICTORINO N.r.-. � N ~0 .:a-~A~-C~ MINDARO-GRULLA Associate Justice 3 !d. at pp. 16-18. 4 !d. pp. 96-104.

RESOLUTION CTA EB No. 1576 (CTA Case Nos. 7523 & 7556) Page 3 of3 MA. BELEN M. RINGPIS-LIBAN Associate Justice (On Leave) CATHERINE T. MANAHAN Associate Justice