COMMISSIONER OF INTERNAL REVENUE v. CENTER FOR TRAINING AND DEVELOPMENT, INC.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY ENBANC COMMISSIONER OF CTA EB No. 1595 INTERNAL REVENUE, (CTA Case No. 8742) Petitioner, Present: -versus- Del Rosario, P.J. Castaneda, Jr., Uy, Pabon-Victorino, Mindaro-Grulla, Ringpis-Liban, and Manahan,JJ. CENTER FOR TRAINING AND Promulgated: DEVELOPMENT, INC., Respondent. DEC 27.2018 -:e1t X------------------------------------------------------------------ ~---/--j-.--�--~---r--o--.--~-X ~ RESOLUTION / , CASTANEDA, JR., J.: Submitted for resolution of the Court En Bane is the Motion for Reconsideration1 filed via registered mail by the Commissioner of Internal Revenue (CIR) on September 13, 2018 with Comment/Opposition (to the Motion for Reconsideration dated September 13, 2018j2 filed by respondent Center for Training and Development, Inc. on October 25, 2018. ~ 1 Court En Bane's Docket, pp. 113-116. 2 /d., pp. 121-123 .

RESOLUTION CTA EB No. 1595 (CTA Case No. 8742) Page 2 of3 In its Motion, petitioner seeks reconsideration of the Decision of the Court En Bane promulgated on August 1, 2018, ("Assailed Decision")3 denying his Petition for Review for lack of merit. In seeking the reversal of the Assailed Decision, petitioner claims that based on paragraph III.B of Revenue Memorandum Order (RMO) No. 12- 2007, Tax Verification Notices (TVN) can be issued in favor of the taxpayer whose case falls below the threshold defined under paragraphs III.A.1.1 to III.A.1.4 of the aforesaid RM0.4 Petitioner maintains that the authority of the revenue officers to investigate the internal tax liabilities of respondent for calendar year 2006 through TVN' s was based on paragraph III.B of RMO No. 12-2007 because its Gross Receipts per VAT Return in the amount of P8,770,446.36 does not exceed the threshold of P1 0,000,000.00 provided under paragraph III.A.l.1 ofRMO No. 12-2007.5 The Court En Bane resolves to deny the present Motion for Reconsideration. The grounds raised by petitioner in his Motion for Reconsideration were already carefully considered, passed upon, and discussed by this Court in the Assailed Decision. The Court En Bane need not belabor anew the errors alleged by petitioner as the conclusions by this Court in the Assailed Decision were reached after judicious study of the parties' respective arguments vis-a-vis the applicable laws, rules, and jurisprudence on the matter. Simply put, there is no compelling reason to disturb the findings in the Assailed Decision. WHEREFORE, petitioner's Motion for Reconsideration is DENIED for lack of merit. SO ORDERED. JJiNITo~.~�~~~A~R. Associate Justice 3 /d., pp. 90-109. 4 /d., p. 114. 5 /d., p. 115.

RESOLUTION ERL~.UY CTA EB No. 1595 (CTA Case No. 8742) Page 3 of3 Associate Justice WE CONCUR: Presiding Justice ESPE CCIEi1LItT;ONN.. MMI~N;DtARwO.-. C ~RU~ LLA Associate Justice ~� ~ --6- (..._' MA. BELEN M. RINGPIS-LIBAN Associate Justice (On Leave) CATHERINE T. MANAHAN Associate Justice