STEFANINI PHILIPPINES INC. v. COMMISSIONER OF INTERNAL REVENUE

,-- REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY Special Second Division STEFANINI PHILIPPINES, CTA CASE NO. 11072 INC., Members: Petitioner, RINGPIS-LIBAN, P.J, Chairperson, MODESTO-SAN PEDRO, and -versus- FERRER-FLORES, JJ COMMISSIONER OF Promulgated: INTERNAL REVENUE, x ------------------------------------~-e-~~~~~=~:~__________________________________________:::~~-~~-JHJ./ R E S0 L U T I 0 N (!ltv . MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Partial Reconsideration (re: Decision promulgated on 14 August 2025), filed on September 8, 2025, assailing this Court's partial grant of the instant Petition for Review through Our August 14, 2025 Decision, with petitioner's Comment/Opposition [to Respondent's Motion for Partial Reconsideration (re: Decision promulgated on 14 August 2025)], filed via registered mail on October 20, 2025. The Motion lacks merit. In his Motion, respondent mainly claims that ( 1) the burden is on the taxpayer to prove its entitlement to a refund sought; and (2) petitioner failed to prove its entitlement as it submitted documents not in compliance with the law's requirements. These are, however, overly general arguments. Respondent does not identify which documents are supposedly not in compliance with the relevant requirements, does not explain how the submission of such documents prevented petitioner from proving its entitlement to the refund sought, and does not show how such claims refute or overturn the Court's own findings as to which requirements petitioner did and did not meet. The Motion consequently provides no cogent reason to reverse Our ruling.,

,- RESOLUTION CTA CASE NO. 11072 Page 2 of2 ACCORDINGLY, respondent's Motion for Partial Reconsideration (re: Decision promulgated on 14 August 2025), filed on September 8, 2025, is hereby DENIED for lack of merit. The assailed Decision, dated August 14, 2025, is AFFIRMED. SO ORDERED. MARlAR WE CONCUR: ~. ~ ) ..___ MA. BELEN M. RINGPIS-LIBAN Presiding Justice c~fi~~ES Associate Justice /