I-CYBERWORLD BIZ, INC. Represented by JACQUELINE GUINTO v. BUREAU OF INTERNAL REVENUE Represented by Commissioner of Internal Revenue CAESAR R. DULAY

CTA Form No.8 (For DCC) 111111111111111111111111111111111111111111111111111111111111111111111111 11111111 22-000150-0080 REPUBLIC OF THE PIDLIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION CTA CASE N0.10827 I-CYBERWORLD BIZ, INC. Represented by JACQUELINE GUINTO, Petitioner, - versus- NOTICE OF RESOLUTION BUREAU OF INTERNAL REVENUE Represented by Commissioner of Internal Revenue CAESAR R. DULAY, Respondent. To: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo St., Legaspi Village Makati City ATTY. FELIX PAUL R. VELASCO ATTY. SYLVIA R. ALMA JOSE ATTY. AYESHA RANIA B. GUILING-MATANOG Bureau of Internal Revenue Room 703, Litigation Division, BlR National Office Building Sen. Miriam P. Defensor-Santiago Avenue Diliman, Quezon City LAYUG CELICIOUS-SY & VILLAPANDO Unit 503, 5th Floor, The Linden Suites 37 San Miguel Avenue Ortigas Center, 1600 Pasig City GREETINGS: You are hereby notified by these presents that on February 20, 2026, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, February 25, 2026. ~nna LAtty. Maria F. Chan-Te \ Executive Clerk of Court III

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION 1-CYBERWORLD BIZ, CTA CASE NO. 10827 INC., Represented by JACQUELINE GUINTO, Members: BACORRO-VILLENA, Acting Chairperson, and Petitioner) CUI-DAVID, JJ. -versus- BUREAU OF INTERNAL REVENUE, Represented Promulgated: by Commissioner of Internal Revenue CAESAR R. DULAY, Respondent. FEB 20 2026 �~.~ffoP/1 ){- - - - - - - - - - - - - - - - - - - - - - - - --~~- - - - - - - - - - - -){ RESOLUTION CUI-DAVID, J.: For resolution of the Court is respondent's Motion for Reconsideration (Re: Decision dated 10 July 2025) filed on July 30, 2025 with petitioner's Comment/ Opposition [Re: Respondent )s Motion for Reconsideration dated July 25) 2025] filed on September 23, 2025. Respondent's Motion for Reconsideration seeks the reversal of the Court's Decision promulgated on July 10, 2025, which granted petitioner's Petition for Review. The dispositive portion of the assailed Decision reads: WHEREFORE, in light of the foregoing, the instant Petition for Review is GRANTED.

RESOLUTION CTA Case No. 10827 I-Cyberworld Biz, Inc., Represented by Jacqueline Guinto v. Bureau of Internal Revenue, Represented by Commissioner of Internal Revenue Caesar R. Dulay x- ------- --- ------------ -- --------- -------- ----------- ----- -------------- ------------------x Accordingly, respondent's Final Assessment Notices dated January 3, 2019 a nd Forma l Letter of Demand dated February 11 , 2019 are hereby CANCELLED and SET ASIDE. Respondent's Fina l Decision on Disputed Assessment dated February 28, 2022,finding petitioner liable for deficiency Final Withholding Taxes and Documentary Sta mp Taxes amounting to P88,299,629.23, inclusive of interest a nd surcharges, for CY 2016, is hereby REVERSED and SET ASIDE. Further, respondent Commissioner of Internal Revenue or any person acting on his behalf is ENJOINED and PROHIBITED from proceeding with the collection of taxes in the above-captioned case. SO ORDERED. Respondent assails the finding of the Court that the Final Assessment Notice and Formal Letter of Demand (FAN/FLD) does not contain a definite due date. Respondent argues that as laid down in Section 228 of the National Internal Revenue Code (NIRC) of 1997, as amended, and Section 3.1.4 of Revenue Regulations (RR) No. 12-1999, as amended by RR No. 18-2013, a taxpayer is given a period of 30 days from receipt of the FLD /FAN within which to file its administrative protest and that upon the expiration thereof without the taxpayer having filed its protest, the assessment shall become final, executory and demandable by operation of law. According to respondent, this m eans that a specific demand from the CIR is not needed because the same is mandated by law. Respondent's argument is unfounded. At the outset, it bears noting that the arguments raised in respondent's Motion for Reconsideration are mere reiterations of issues that were already thoroughly considered, discussed, and resolved in the assailed Decision. It is well-settled that a motion for reconsideration containing mere reiterations or rehashes of grounds and arguments previously considered, weighed, and resolved by the court before the Decision sought to be reconsidered is rendered , does not require a n ew judicial determination.1 Thus, there is no necessity to discuss and rule again on this ground since "this People v. Agacer. G.R. o. 17775 1. January 7. 20 13 lPcr J. Del Casti llo. Special First Di vision] citing People v. Larrai'iaga. G.R. os. 138874-75. July 2 1. 2005 [Per Curiam. En Bane]: i\1/endo=a-Ong v. Hon. Sandiganbayan. , G.R. Nos. 146368- 69. October 18. 2004 [Per J. Quisum bing. Special Second Division].

RESOLUTION CTA Case No. 10827 1-Cyberworld Biz, Inc. , Represented by Jacqu eline Guinto v. Bureau of Internal Revenue, Represented by Commissioner of Internal Revenue Caesar R. Dulay Page 3 of4 x------------------------------------------------------------------------------------------x would be a useless formality of ritual invariably involving merely a reiteration of the reasons already set forth in the judgment or final order for rejecting the arguments advanced by the movant."2 In Shangri-La International Hotel Management, Ltd. v. Developers Group of Companies, Inc. , 3 the Supreme Court emphasized that it is incumbent upon the movant to convince the Court that certain findings or conclusions are contrary to law, as follows: The bulk of the aforementioned grounds is a mere rehash of mova nt's previous arguments. While DGCI is correct in stating that a motion for reconsideration, by its very nature, m ay tend to dwell on issues a lrea dy resolved in the decision sought to be reconsidered and that this should n ot be an obstacle for a reconsideration, the h ard reality is tha t movant has fa iled to ra ise matters substantially plausible or compellingly persuasive to warrant the desired course of action. Considering that the grounds presently raised have been sufficiently considered, if not squarely addressed, in the subject Decision, it behooves movant to convince the Court that certain findings or conclusions in the Decision are contrary to law. As it is, however, th e instant motion does n ot raise any new or substantial legitimate ground or reason to justify the reconsideration sought. Thus, where the grounds raised have been sufficiently addressed in the decision, it is incumbent upon the movant to demonstrate that the Court's findings are contrary to law. In this case, respondent failed to raise any new, material, or persuasive argument to justify a reversal or modification of the Court's ruling. Accordingly, the Court reaffirms its findings that the FLD dated February 11, 2019 and the FAN issued on January 3 , 2019 are void for failure to indicate the due date. The requirement to indicate the due date has been clearly settled by Commissioner of Internal Revenue v. Fitness by Design, Inc., 4 where the Supreme Court ruled that for a tax assessment to be valid, it must contain a demand for payment and a definite due People v. Agacer. G.R. o. 177751. January 7. 2013 !Per J. Del Castillo. Special First Di vision] citing People v. Larraiiaga. G.R. os. 138874-75. July 2 1. 2005 [Per Curiam. En Bane] and Ortigas and Co. Ltd. Partnership v. Judge J'elasco. G.R. o. 109645. March 4. 1996 [Per J. arvasa. Third Division]. G.R. o. 159938. January 22. 2007 [Per J. Garcia. First Division]. citing Ortigas and Co. Ltd. Parmership v. Judge J'elasco, G.R. No. I09645. March 4, 1996 [Per C.J. arvasa. Third Division]. G.R. No. 2 15957. ovember 9. 20 16 [Per J . Leonen. Second Division! .

RESOLUTION CTA Case No. 10827 I-Cyb erworld Biz, Inc., Represented by Jacqueline Guinto v. Bureau of Interna l Revenue, Represented by Commissioner of Internal Revenue Caesar R. Dulay Page 4 of4 x--------------- ---------------------------------------------------------------------------x date. The findings of the Court remain unrebutted: the FLD and FAN indicated a due date of January 31, 20 19, but were only received by petitioner on February 12, 2019, after the due date had already lapsed thereby affecting the definiteness of the tax liability stated in the assessment. WHEREFORE, premises considered, respondent's Motion for Reconsideration (Re: Decision dated 10 July 2025) is DENIED for lack of merit. SO ORDERED. LAN!lLrtf~.AvJA~Alnh-DrA�\JnD Associate Justice !CONCUR: