SERVICE RESOURCES, INC. v. COMMISSIONER OF INTERNAL REVENUE

CTA Fonn o. 8 (For DCC) 111111111111111111111111111111111111111111111111111111111 11111 111111111111111111 21-000151-0062 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION CTA CASE N0.10503 SERVICE RESOURCES, INC., Pe titi o ner , - versus - NOTICE OF RESOLUTION COMMISSIONER OF INTERNAL REVENUE, Respondent. To: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo Street, Legazpi Village Makati City ATTY. LIEZL G. BOHOL Bureau of Internal Revenue-Revenue Region No. 78 25th Floor, Legal Division, The Podium West Tower 12 ADB Avenue, Ortigas Center Mandaluyong City D U-BALADAD & ASSOC IATES 20th Floor, Chatham House Rufino comer Valero Streer Salcedo Village, Makati City G R E E T IN GS: You are hereby notified by these presents that on January 16, 2025, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, January 17, 2025. Atty. Mar rette Y. Gu Executiv Clerk of Court Page I of I

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION SERVICE RESOURCES, INC., CTA Case No. 10503 Petitioner, Members: -versus- DEL ROSARIO, P.J., Chairperson, MANAHAN, and REYES-FAJARDO, JJ. COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. J{- - - - - - - - - - - - - - - - - - - - - - - - MANAHAN, J.: Sub mitted before the Court is respondent's Motion for Reconsideration (on the Decision dated July 5, 2024) filed on July 30, 2024, with petitioner's Comment (on Respondent's Motion for Reconsideration [Re: Decision dated July 5, 2024] dated July 29, 2024) filed on September 4, 2024. On July 5, 2024, the Court promulgated a Decision, partially granting petitioner's claim for refund of eJ<cess and unu tilized creditable withholding taJ< (CWT) for taJ<able year 2018, th e dispositive portion of which is stated below, to wit: "WHEREFORE, in light of the foregoing considerations, the present Petition for Review is PARTIALLY GRANTED . Accordingly, respondent is ORDERED TO REFUND in favor of petitioner, the reduced amount of P17,851 ,271.40, representing the latter's excess and unutilized CWTs forTY 2018. SO ORDERED." ~

RESOLUTION CTA Case No. l 0503 In his Motion, respondent primarily argues that the foremost requirement in order for a claim for tax refund to prosper is that the refund application must be accompanied by complete documentary support for the Bureau of Internal Revenue (BIR)'s verification. He continues that in case of recovery of excess and unutilized CWTs, such as in the present case, petitioner must prove compliance with the governing rules relative to tax refund as provided under Sections 76, 204(C) and 229 of the 1997 National Internal Revenue Code (NIRC), as amended. Citing the Dissenting Opinion of Presiding Justice Roman G. Del Rosario in the assailed Decision dated July 5, 2024, respondent submits that petitioner failed to prove compliance therewith, arguing that allowing the refund of CWTs pertaining to petitioner's alleged branches without presenting their respective BIR Certificates of Registration is improper. Lastly, respondent maintains that in an action for tax refund, the burden of proof rests upon the taxpayer to establish by sufficient and competent evidence its entitlement thereto and failure to adduce sufficient proof is fatal to its claim for tax refund. On the other hand, in its Comment, petitioner points out that respondent did not raise any new matter or arguments in his Motion for Reconsideration. Petitioner asserts that the arguments proffered by respondent are mere rehash of the allegations stated in his Answer filed on November 8, 2021 1, and all of which had been thoroughly and carefully considered by this Court in the Decision promulgated on July 5, 2024. Nonetheless, pebtwner disagrees with respondent's argument that it failed to prove its compliance with the governing rules relative to tax refund, as the Court correctly held that it has sufficiently proven its entitlement to a refund in the amount of 1'17,851,271.40, representing its excess and unutilized CWTs for taxable year 2018. Petitioner insists that it had complied with all the requisites in a claim for CWT refund, i.e., (a) the administrative and judicial claims for refund were made within the two-year prescriptive period; (b) the income upon which the unutilized CWT were withheld and were declared as part of petitioner's gross income; and (c) the fact of withholding of the unutilized CWT for taxable year 2018 is duly established. ~ 1 Docket-Val. I, pp. 73 to 77.

RESOLUTION CTA Case No. I 0503 RULING OF THE COURT After due consideration, the Court finds respondent's Motion for Reconsideration bereft of merit. As correctly observed by petitioner, the arguments raised by respondent in his Motion are a mere rehash of the previous arguments, which have already been duly considered, discussed and resolved in the assailed Decision. Moreover, respondent's arguments herein are mere generic arguments - stating that petitioner failed to prove its compliance with the governing rules relative to tax recovery or refund - without even specifying the findings or conclusions of the Court alleged to have not been supported by the evidence or which are contrary to law, as required by Section 2, Rule 37 of the Rules of Court.2 Nonetheless, as to respondent's contention that it was improper to allow the refund of CWTs pertaining to petitioner's branches without presenting the latter's BIR Certificates of Registration, the Court is not swayed. Again, so long as the payee is under petitioner's registered name and the first nine digits of petitioner's Taxpayer Identification Number (TIN), or the TIN proper, were correctly indicated on the Certificates of Creditable Tax Withheld at Source (BIR Forms No. 2307), the corresponding BIR Form No. 2307 is still considered complete in relevant details, since the same is sufficient to aid the Court in the evaluation of the claim for refund in this case. As held in Commissioner of Internal Revenue v. Philippine National Bank, 3 the Certificate of Creditable Tax Withheld at Source (BIR Form No. 2307) that is ' "SEC. 2. Conte11ts of mot.ion for 11ew trial or reconsideration and 1Wlice thereo/ The motion shnll be made in writing stc::l1_ing the ground or grounds therefor, a \Vrit.tcn notice of which shall lle served by the movant on the adverse party. X X X. A motion for reconsideration shall point out specifically the findings or conclusions of the judgment or final order which are not supported by the evidence or which are contrary to law, making express reference to the testimonial or documentary evidence or to the provisions of law alleged to be contrary to such findings or conclusions. 1\ pro forma motion for ncvv trial or reconsideration shall not toll the reglcmentary period of appeal." (Jcmphoses supplied) .l G.l�i. No. 180290, September 29,2014. ~

RESOLUTION CTJ\ Case No. l 0503 complete in relevant details, is the competent proof to establish the fact that taxes are withheld, to wit: "The certificate of creditable tax withheld at source is the competent proof to establish the fact that taxes are withheld. It is not necessary for the person who executed and prepared the ccrlificalc of creditable lax withheld al source to be presented and to testify personally to prove the authenticity of the certificates. In Banco Filipino Savings and Mortgage Bank v. Court of Appeals, this court declared that a certificate is complete in the relevant details that would aid the courts in the evaluation of any claim for refund of excess creditable withholding taxes: In fine, the document which may be accepted as evidence of the third condition, that is, the fact of withholding, must emanate from the payor itself, and not merely from the payee, and must indicate the name of the payor, the income payment basis of the tax withheld, the amount of the tax withheld and the nature of the tax paid. At the time material to this case, the requisite information regarding withholding taxes from the sale of acquired assets can be found in BIR Form No. 1743. I. As described in Section 6 of Revenue Regulations No.6- 85, BIR Form No. 1743. I is a wriUcn statement issued by the payor as withholding agent showing the income or other payments made by the said withholding agent during a quarter or year and the amount of the lax deducted and withheld therefrom. lt readily identifies the payor, the income payment and the tax withheld. It is complete in the relevant details which would aid the courts in the evaluation of any claim for refund of creditable withholding taxes. (Emphasis supplied, citations omitted) Moreover, as correclly held by the Court of Tax Appeals En Bane, the figures appearing in the withholding lax certificates can be taken at face value since these documents were executed under the penalties of perjury, pursuant to Section 267 of the 1997 National Internal Revenue Code, as amended, which reads: XXX Thus, upon presentation of a withholding tax certificate complete in its relevant details and with a written statement that it was made under the penalties of perjury, the burden of evidence then shifts to the Commissioner of Internal Revenue to prove that (1) the ~

RESOLUTION CTA Case No. 10503 certificate is not complete; (2) it is false; or (3) it was not issued regularly." (Emphasis added) In relation thereto, Revenue Regulations (RR) No. 07- 2012,4 provides that the TIN comprises of a nine (9) to thirteen (13) digit numeric code where the first 9 digits is the TIN proper and the last 4 digits is the branch code, to wit: "SECTION 3. DEFINITION OF TERMS. For purposes of these Regulations, the following words and/or phrases shall be defined as follows: 1. X X X. Primary Registration may involve two scenarios depending on the purpose of the taxpayer applying for registration as follows: 1. TIN ISSUANCE AND REGISTRATION - refers to issuance of TIN to all persons who will engage in business, practice of profession or employment and who may or may not be subject to any national internal revenue tax but may be required to file the corresponding lax return, statement or other documents as required by the Code such as: income tax, estate and donor's tax, value added tax, percentage lax, withholding tax, excise tax and documentary stamp tax (DST), including registration of its branch/es (for purposes of securing a branch code); 2. X X X. 3. 'Taxpayer Identification Number (TIN)'- shall pertain to the system-generated reference index number issued and assigned by the BlH to each and every person registered in its database. xxx. The TIN comprises of a 9 to 13 digit numeric code where the first 9 digits is the TIN proper and the last 4 digits is the branch code. The branch code digits may be increased depending on future systems enhancements and policy declarations of the Commissioner of Internal Revenue (CIR)-" 1 "SUB,JECT: Amended Consolidated l~cvcnuc l~cgulations on Primary l~cgistration, Updates, 1\nd Cancellation"', dated 1\pri\ 2, 2012. �1 Previously, the branch cocic consists of the last three digits, refer Lo Section 5, RENo. 11-99 [SUB.JI�:CT: Prescribing the Issuance of Taxpayer Identification Number (TIN) t.o All Taxpa_yers and Qualified 1\pplicant.s and the Mandatory Incorporation of TIN in Government Fonns, Papct�s or Docutncnt.s]. Now, the branch code consists of the last five digits of the 14-cligit TIN, refer to Revenue Mcmorandun1 Circular No. 74-2019 [SUBJECT: Circularizing the /\vailabiliiy of the Enhanced BIR Form Nos. 2306 &. 2307 January 2018 (l�:NCS)J . ..,~~1..__ _

RESOLUTION CTA Case No. 10503 4. X X X. 5. X X X. 6. 'Head Office (HO)' - refers to the declared specific or identifiable principal place/head office of business as stated in the Articles of Incorporation/ Articles of Partnership/ Articles of Cooperation/DTI Certificate of Registration, as the case may be, or, in the absence thereof, the place where the complete books of accounts are kept. xxx. 7. 'Branch'- means a separate or distinct establishment or place of business where sales transactions arc conducted independently from the HO. For purposes of these Regulations, branch shall include the following: XXX SECTION 9. REQUIREMENT FOR THE REGISTRATION OF EACH TYPE OF INTERNAL REVENUE TAX. - Every person, who is required to register with the BIR under Section 4 of these Regulations, shall register each type of internal revenue tax for which he/it is obligated to file a return or pay taxes due thereon. Such person shall update the BIR for any changes in his/ its registration information in accordance with Section 1 1 hereof. XXX vrz. Registration for Withholding Tax. The registration for lhc pertinent withholding lax types shall be made by all withholding agents, such as NGAs and its instrumentalities, GOCCs, LGUs including certain tax- exempt entities. They shall likewise register the applicable tax types on their proprietary function. XXX With respeel lo business entities with branch/ es, the rules on the registration of tax types as provided hereunder shall be observed: 1) Registration shall be with the HO only 1. Income Tax 11. VAT x x x." (Emphases and underscoring supplied) arc

RESOLUTION CTA Case No. 10503 Moreover, in Section 236(I)6 of the 1997 NIRC, as amended, the purpose of indicating the TIN in the return, statement, or document filed with the BIR is mainly for proper identification for tax purposes7 Accordingly, it can be gathered from the foregoing that income tax is always on a consolidated return for the head office and branch/ es. Thus, all Certificates of Creditable Tax Withheld at Source (BIR Forms No. 2307) of the head office and branch/es shall be attached to and covered by a consolidated return to be filed by the head office. With this consolidated filing, wherein the TIN of the head office is used to file the consolidated return, all BIR Forms No. 2307 whether issued under the TIN of the head office or under the TIN of the branch/ es should therefore be recognized. Hence, denial into evidence of the Certificates of Registration of petitioner's branches is not a sufficient ground to disallow the corresponding CWTs as the Court can still verify the TIN proper from the Certificate of Registration8 of the head office of petitioner. Perforce, by correctly indicating the first 9 digits of the 12- digit payee's (petitioner's) TIN in BIR Form No. 2307, the purpose of properly identifying the payee-taxpayer was achieved. Again, the last three digits of the TIN (or the branch code) will eventually be disregarded as the head office and branch/ es are treated as one and the same for income tax and creditable withholding tax purposes, since the BIR Forms No. 2307 whether issued to the head office or branch/ es are attached to and covered by a consolidated return using the TIN of the head office, which has a branch code of "0000". Consequently, even if the payee's TIN indicated in BIR Form No. 2307 is allegedly for a branch, based on the branch code, the ''Renumbered to Section 236(11) under I<cpublic 1\cl No. 11976 or the "Ease of Paying Taxes Act." 1 "SEC. 236. Reqistruiion Requirements. XXX (I) Supplying of Tuxpayer Irlentijiculion Number (TIN). - 1\ny person required under the authority of this Code to make, render or file a return, statenlCnt or other document shall be supplied with or ~1ssigncd a Taxpayer Identification Number (TIN) which he shall indicate in such return, statement or document filed \\'iLh the Bureau of lntcrn<ll I\evenue for his proper identification for tax purposes, and which he shall indicate in certain documents, such ns, but not limited to, the following: x x x." {l~mphosis supplied) K ~xhibi1 "P-7".Q t

RESOLUTION CTA C8sc No. 10503 BIR Form No. 2307 will still be attached to and covered under the consolidated return of the head office. In any case, the branch code of petitioner's branches may also be ascertained in their Authority to Print,9 which were offered in evidence in the present case. For the said reasons, the Court was able to verify and ascertain that petitioner has sufficiently proven its entitlement to a refund in the amount of '1'17,851,271.40, representing its excess and unutilized CWTs for the taxable year 2018. Tax refunds or tax credits, just like tax exemptions, are strictly construed against taxpayers, the latter having the burden to prove strict compliance with the conditions for the grant of the tax refund or credit. 10 This is the reason why a taxpayer must positively show compliance with the statutory requirements provided for under the 1997 NIRC, as amended, in order to successfully pursue its claim. 11 However, in this case, once the taxpayer has sufficiently proven its entitlement, it is incumbent upon the government to refund what is warranted under the law. In view of the foregoing disquisitions, there being no new matters or substantial issues raised in respondent's Motion for Reconsideration, the Court finds no compelling reason to reverse or modify the assailed Decision promulgated on July 5, 2024. WHEREFORE, premises considered, respondent's Motion for Reconsideration (on the Decision dated July 5, 2024) is DENIED for lack of merit. SO ORDERED. c~� 7- /J<..:;..c.c.._L_. __ CATHERINE T. MANAHAN Associate Justice !J Exhibits "P-3256" to ''P-3257", "P-3260", "P-3262" to "P-3267", and "P-3269". 1o Commissioner of Jnterncll Revenue v. J\1irant Fubiluo C01porution (now Tea~! Enerm; COJporution}, G.R. No. 180434, ,January 30, 2016. 1 1 Winebrenner & !Jligo Jnsurcwce Urokers, Inc. u. Corrunissioner (~{Internal Neuenue, G .I~. No. 206526,JRnURD 28,2015.

RESOLUTION CTi\ Case No. 10503 Page(_) of 9 WE CONCUR: (With Separate Opz zan) ROMAN G. DEL ROSARIO Presiding Justice M~ ARIAN 1-{ijiU'JFv.f.RE~~S--FA~.J~ARDO Associate Justice

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION SERVICE RESOURCES, INC., CTA CASE NO. 10503 Petitioner, Members : -versus- DEL ROSARIO, P.J. , Chairperson , MANAHAN, and REYES-FAJARDOI JJ. COMMISSIONER OF INTERNAL Promulgated: REVENUE , SEPARATE OPINIO DEL ROSARIO, P.J.: While I concur in the denial of respondent's Motion for Reconsideration (on the Decision dated July 5, 2024) for lack of merit thereby affirming the partial grant of petitioner's refund claim , I cannot subscribe to the ponencia's view that so long as the creditable withholding tax (CWT) certificates indicate petitioner's registered name (Service Resources, Inc.) and the first nine digits of its Taxpayer Identification Number (TIN) (000-144-056 ), said certificates are considered "complete in relevant details" to aid the Court in the eva luation of petitioner's claim for refund.1 Section 3(3) of Revenue Regulations (RR) No. 7-20122 defines the TIN as "the system-generated reference index number issued and assigned by the [Bureau of Internal Revenue (BIR)] to each and every person registered in its database." It further clarifies that the TIN comprises of a 9 to 13-digit numeric code where the first 9 digits is the TIN proper and the last 4 digits is the branch code . 1 Resolution, p. 3 2 Subject: Amended Consolidated Revenue Reg ulations On Primary Reg istration, Updates, And Cancellation, dated April 2 , 2011Yl

SEPARATE OPINION Service Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 For the CWTs attributable to transactions originating from the taxpayer's home office, the payee's name, TIN, and address, as reflected in the CWT certificates, can be verified through various documents such as the BIR Certificate of Registration or the tax returns filed by the taxpayer. On the other hand, for the CWTs attributable to the transactions originating from the taxpayer's branches, without the BIR Certificates of Registration or Authority to Print (ATP), the Court cannot verify whether the TINs reflected in the CWT certificates indeed pertain to the taxpayer's branches or whether the purported branches even exist in the first place. In my view, allowing the refund of CWTs attributable to a branch based solely on a CWT certificate issued under the taxpayer's name but bearing a TIN and an address different from the home office's address without first establishing the existence of the branch that owns those details, fails to present a clear case for refund. Instead, it raises doubt as to whether the CWT is refundable at all. In Sony Philippines Incorporated vs. Commissioner of Internal Revenue, 3 I held the view that even though the taxpayer's TIN is incomplete, if the CWT certificates indicate the taxpayer's registered name and address and the same can be cross-referenced to the submitted BIR Certificate of Registration, then the CWT certificates may be considered complete in relevant details necessary to aid the Court in evaluating the subject refund claim. Similarly, I hold the view that even though the taxpayer's address is incomplete or erroneous, for as long as the taxpayer's registered name and TIN are reflected in the CWT certificate, such certificate is considered "complete in relevant details". In sum, for as long as two of the three important details (registered name, TIN, and address) are correctly indicated in the CWT certificate, such certificate may be considered "complete in relevant details". In the case at bar, only the registered name of petitioner is correctly indicated in the CWT certificate. The TIN, and the address indicated therein do not pertain to its home office but to a purported branch, which is considered by law as "a separate or distinct establishment or place of business where sales transactions are conducted independently from the [home office]" 4 The CWT certificate 3 CTA Case No. 10115, December 16,2021. 4 Section 3 (7), RR 7-2012C!J1

SEPARATE OPINION Service Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 may pertain to a branch transaction but the particular branch is not known or whether such branch even exists. In its Formal Offer of Evidence, petitioner appears to acknowledge the need to establish the existence of the branches before the CWTs issued under them may be considered. Petitioner submitted the branches' BIR Certificates of Registration5 "to prove that Petitioner is (a) registered taxpayer with the Bureau of Internal Revenue; (b) entitled to refund its excess and unutilized CWT for taxable year 2018 in the amount ofP20,695,542.15"6 and their ATPs7 "to prove that Petitioner is (a) authorized to print receipts or sales or commercial invoice before a printer can print the same and (b) entitled to its claim for refund of unutilized CWT for taxable year 2018 in the amount of P20, 695,542. 15". 8 In the assailed Decision, the Court granted the refund of ~17,851 ,271.40. As shown below, tracing and re-computation procedures revealed that out of said amount, 89.57% or ~15,990,037.72 arose from the branches' transactions: Source CWT % Home Office 1,861,233.91 10.43% Branches 15,990,037.72 89.57% Total 17,851,271.639 Given that majority of petitioner's CWTs arose from transactions involving its branches, it becomes imperative for the Court to verify that such transactions indeed pertain to petitioner's branches. Failure to do so may result in the Court inadvertently granting a refund of ~15,990,037. 72 which petitioner may not actually be entitled to. As the BIR Certificates of Registration of petitioner's purported branches were not admitted in evidence, 10 the ATPs may be referred to in validating the CWTs attributable to its branches. Summarized below are the branches respective TINs and addresses: 'Exhibits "P-7-A" to "P-7-F" 'Formal Offer of Evidence, Docket, p. 507. 7 Exhibits "P-3255" to "P-3269". 8 Formal Offer of Evidence ,Docket p. 514 9 A negligible difference of 1".23 arose from the tracing and re-computation procedures conducted. 10 Resolution dated December 5, 2022, CTA Docket, Vol. II, pp. 904-90{)f}

SEPARATE OPINION Service Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 HOME Clark Branch Sta. Rosa, BRANCH Batangas Cavite Branch OFFICE Laguna Branch Branch Calamba, Laguna Branch TIN 000-144-056- 000-144-056- 000-144-056- 000-144-056- 000-144-056- 000-144-056- 000 001 002 003 004 005 FIRST FIRST 2ND FLR., CAPITOL OFFICE UNITED UNIT 209-211 NATIONAL GROUND FLR. FARMERS DANHEDAN PLACE G/F CENTER5B BANK BLDG BLDG. BRGY. HIGH WAY K3 BLDG. STA. ROSA UNO ST. COR. BERTHAPIL COMMERCIAL CROSSING #57 STA GOVERNOR'S PHIL-AM COMPLEX CALAMBA Address Ill JOSE STA. ROSA CITY LAGUNA ANASTACIA DRIVE BRGY. CITY LAGUNA STS., ABAD STO TOMAS SAMPALOC I KAPITOLYO SANTOS BATAN GAS DASMARINAS PASIG CITY AVE. CLARK CITY CAVITE FREEPORT ZONE Exhibit P-3257 P-3258; P- P-3256; P- P-3262 P-3265 No. P-3255; P- 3269 3263; P-3266; 3261; P-3268 P-3267 (USB) After a painstaking comparison, I agree that it is proper to grant petitioner the refund of P17,851 ,271.40, broken down below, which includes those pertaining to the branches amounting to P15,990,037. 72: Exhibit Payor's Name CWT granted HO/Branch per Decision P-3275 P-3276 First Quarter P-3277 P-3278 Alteza Realty Corp 3,795.00 Home Office P-3280 79,249.45 Batanqas Branch P-3281 Bandai Namco Philippines, Inc. 57,674.17 Batangas Branch P-3282 53,267.48 Batangas Branch P-3283 Bandai Namco Philippines, Inc. 43,291.89 Batanqas Branch P-3284 417,502.40 Batangas Branch P-3285 Bandai Namco Philippines, Inc. Home Office P-3286 9,982.14 Home Office P-3287 Bandai Namco Philippines, Inc. 10,107.14 Home Office P-3288 Calamba, Laquna Branch P-3289 Brother Industries (Philippines) Inc. 9,515.32 Calamba, Laquna Branch P-3290 Central Services lnteqrated Cooperative 540 08 Calamba, Laguna Branch P-3291 Batangas Branch P-3292 Central Services lnteqrated Cooperative 1,170.06 Batangas Branch P-3293 1,013.80 Batangas Branch P-3295 EHS Lens Philippines, Inc. 33,825.75 Batangas Branch P-3296 83,702.00 Home Office P-3300 EMD Technologies Philippines, Inc. 74,857.89 P-3301 146,684.98 Cavite Branch P-3302 EMD Technologies Philippines, Inc. 7,995.79 Sta. Rosa, Laguna Branch P-3303 Home Office EMD Technologies Philippines, Inc. 1,800,767.89 Calamba, Laquna Branch 49,260.73 Calamba, Laguna Branch Fuji Industries Manila Corp. 63,853.14 Calamba, Laguna Branch 564.71 Calamba, Laguna Branch Fuji Industries Manila Corp. 12,487.22 109.80 Cl; Fuji Industries Manila Corp. 14,555.72 IM Digital Philippines, Inc. Island Quarry & Aqrregates Corporation JAE PHILS INC Katolec Philippines Corporation Nanox Philippines, Inc. NYK Auto Logistics Philippines Inc NYK Auto Logistics Philippines Inc NYK Auto Logistics Philippines Inc NYK Auto Logistics Philippines Inc

SEPARATE OPINION Service Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 P-3304 NYK Auto Loqistics Philippines Inc 13,084.85 Calamba, Laquna Branch P-3305 NYK Auto Logistics Philippines Inc 10,987.30 Calamba, Laquna Branch P-3306 Pasig First Capitol Realty Corp Home Office P-3307 People-Link Staffing Solutions, Inc. 3,795.00 Home Office P-3308 People-Link Staffing Solutions., Inc. 500.00 Home Office P-3315 Sanna Philippines Manufacturinq Corporation 500.00 Cavite Branch P-3316 Sanna Philippines Manufacturinq Corporation Cavite Branch P-3317 San no Philippines Manufacturing Corporation 13,842.92 Cavite Branch P-3318 San no Philippines Manufacturing Corporation 16,844.74 Cavite Branch P-3319 San no Philippines Manufacturinq Corporation 16,057.90 Cavite Branch P-3320 Sanna Philippines Manufacturino Corporation 11,082.30 Cavite Branch P-3321 Solid Cement Corp. 15,889.43 Home Office 17,906.01 P-3323 Southern Asia-Pacific Division Corp of General 34,258.16 Conference of Seventh-Day Adventists P-3324 436.78 Cavite Branch Southern Asia-Pacific Division Corp of General P-3325 Conference of Seventh-Day Adventists 512 08 Cavite Branch P-3326 Southern Asia-Pacific Division Corp of General 543.11 Cavite Branch Conference of Seventh-Day Adventists P-3327 341.39 Cavite Branch Southern Asia-Pacific Division Corp of General P-3328 Conference of Seventh-Day Adventists 516.95 Cavite Branch P-3329 P-3330 Southern Asia-Pacific Division Corp of General 1,265.00 Home Office P-3331 Conference of Seventh-Day Adventists 1,265.00 Home Office P-3332 1,265.00 Home Office P-3333 Second Quarter 42,500.09 Batangas Branch P-3334 Alteza Realty Corp 33,336.01 Batanqas Branch P-3335 Alteza Realty Corp 33,450.92 Batangas Branch P-3336 Alteza Realty Corp 26,081.13 Batanoas Branch P-3337 Bandai Namco Philippines, Inc. 32,405.74 Batangas Branch P-3338 Bandai Namco Philippines, Inc. 35,662.93 Batangas Branch P-3339 Bandai Namco Philippines, Inc. 564,217.99 Batanqas Branch P-3340 Bandai Namco Philippines, Inc. 8,999.71 Home Office P-3341 Bandai Namco Philippines, Inc. 1,103.10 Calamba, Laquna Branch P-3342 Bandai Namco Philippines, Inc. 1,118.95 Calamba, Laquna Branch P-3343 Brother Industries (Philippines) Inc. 1,093.31 Calamba, Laguna Branch P-3344 EHS Lens Philippines, Inc. 79,335.80 Batangas Branch P-3345 EMD Technoloqies Philippines, Inc. 77,396.37 Batanqas Branch P-3346 EMD Technoloqies Philippines, Inc. 81' 133.87 Batanoas Branch P-3347 EMD Technologies Philippines, Inc. 269,170.70 Batangas Branch P-3349 Fuji Industries Manila Corp. 21,306.08 Home Office P-3350 Fuji Industries Manila Corp. P-3351 Fuji Industries Manila Corp. 2,973,349.79 Cavite Branch P-3352 IM Diqital Philippines, Inc. 47,384.52 Sta. Rosa, Laguna Branch P-3353 Island Quarrv & Aqrreqates Corporation 45,379.94 Home Office P-3355 13,719.45 Calamba, Laguna Branch P-3356 JAE PHILS INC 611.33 Calamba, Laguna Branch P-3357 Katolec Philippines Corporation 14,541.46 Calamba, Laquna Branch P-3358 Nanox Philippines, Inc. 66.00 Calamba, Laquna Branch P-3359 NYK Auto Logistics Philippines Inc 313.73 Calamba, Laguna Branch P-3360 NYK Auto Logistics Philippines Inc 13,368.48 Calamba, Laguna Branch P-3361 NYK Auto Loqistics Philippines Inc 2,218.61 Calamba, Laguna Branch P-3362 NYK Auto Logistics Philippines Inc 13,378.87 Calamba, Laguna Branch P-3363 NYK Auto Logistics Philippines Inc 48.73 Calamba, Laguna Branch P-3364 NYK Auto Logistics Philippines Inc 17,744.02 Calamba, Laguna Branch NYK Auto Logistics Philippines Inc 29.06 Calamba, La0una Branch NYK Auto Loqistics Philippines Inc 410.30 Calamba, Lacuna Branch NYK Auto Loqistics Philippines Inc 1,265.00 Home Office NYK Auto Loqistics Philippines Inc NYK Auto Looistics Philippines Inc NYK Auto Logistics Philippines Inc Pasig First Capitol Realty Corp

SEPARATE OPINION Service Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 P-3365 Pasiq First C<ljJitol Realty Corp 1,265.00 Home Office P-3366 1,265.00 Home Office P-3368 Pasig First C"flitol Realty Corp 128,182.94 Home Office P-3370 131,716 04 Home Office P-3373 Pricon Microelectronics Inc. 15,677.99 Cavite Branch P-3375 14,671.26 Cavite Branch P-3376 Pricon Microelectronics Inc. 17,359.15 Cavite Branch P-3377 16,790.32 Cavite Branch P-3378 Sanna Philippines Manufacturinq Corporation 18,009.56 Cavite Branch P-3379 86,219.65 Home Office Sanna Philippines Manufacturinq Corporation P-3380 San no Philippines Manufacturing Corporation P-3381 Sanna Philippines Manufacturing Corporation P-3382 Sanna Philippines Manufacturing Corporation P-3383 Solid Cement Corp. P-3384 Southern Asia-Pacific Division Corp of General 531.66 Cavite Branch P-3385 Conference of Seventh-Day Adventists P-3386 P-3387 Southern Asia-Pacific Division Corp of General 532.03 Cavite Branch P-3388 Conference of Seventh-Day Adventists P-3389 P-3390 Southern Asia-Pacific Division Corp of General 620.24 Cavite Branch P-3391 Conference of Seventh-Day Adventists P-3392 P-3393 Southern Asia-Pacific Division Corp of General 620.65 Cavite Branch P-3394 Conference of Seventh-Day Adventists P-3395 P-3396 Southern Asia-Pacific Division Corp of General 664.74 Cavite Branch P-3397 Conference of Seventh-Day Adventists P-3398 P-3399 Third Quarter P-3400 P-3401 Alteza RealtyCorp 1,265.00 Home Office P-3402 1,265.00 Home Office P-3403 Alteza Realty Corp 1,265.00 Home Office P-3404 40,035.95 Batanqas Branch P-3405 Alteza Realty Corp 34,591.02 Batangas Branch P-3406 41,924.76 Batanqas Branch P-3407 Bandai Namco Philippines, Inc. 35,591.98 Batangas Branch P-3408 35,806.60 Batangas Branch P-3409 Bandai Namco Philippines, Inc. 35,100.52 Batanqas Branch P-341 0 609,115.59 Batangas Branch P-3411 Bandai Namco Philippines, Inc. 1,204.69 Home Office P-3412 1,050.82 Calamba, Laguna Branch P-3413 Bandai Namco Philippines, Inc. 1,199.35 Calamba, Laquna Branch P-3414 1,167.09 Calamba, Laquna Branch P-3415 Bandai Namco Philippines, Inc. 72,947.38 Batangas Branch P-3416 76,195.55 Batangas Branch P-3417 Bandai Namco Philippines, Inc. 89,951.15 Batanqas Branch P-3418 343,997.76 Batangas Branch P-3419 Brother Industries (Philippines) Inc. 7.604.06 Home Office P-3420 3,052,482.05 Cavite Branch P-3421 EHS Lens Philij:lpines, Inc. 52,403.65 Sta. Rosa, Laguna Branch Home Office EMD Technologies Philippines, Inc. 638.40 Home Office 8,497.50 Home Office EMD Technologies Philippines, Inc. Home Office 220.40 Home Office EMD Technologies Philippines, Inc. 8,618.80 Home Office 8,780.29 Home Office Fuji Industries Manila Corp. Home Office 311.60 Home Office Fuji Industries Manila Corp. 136,658.96 Home Office 128,378.66 Calamba, Laguna Branch Fuji Industries Manila Corp. Calamba, Laguna Branch 2,376.00 Calamba, Laguna Branch IM Digital Philippines, Inc. 116,504.58 Calamba, Laguna Branch Calamba, Laguna Branch Island Quarrv & Aqrreqates Corporation 31.37 Calamba, Laquna Branch 15,747.94 JAE PHILS INC 16,683.22 Katolec Philippines Corporation 164.34 163.35 Nanox Philippines, Inc. 16,140.36 Nanox Philippines, Inc. Nanox Philippines, Inc. Nanox Philippines, Inc. Nanox Philippines, Inc. Nanox Philip~ines, Inc. Nanox Philippines, Inc. Nanox Philippines, Inc. Nanox Philippines, Inc. Nanox Philippines, Inc. NYK Auto Logistics Philippines Inc NYK Auto Loqistics Philippines Inc NYK Auto Logistics Philippines Inc NYK Auto Loqistics Philippines Inc NYK Auto Loqistics Philippines Inc NYK Auto Loqistics Philippines Inc

SEPARATE OPINION Se1vice Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 P-3422 NYK Auto Logistics PhiliPPines Inc 328.24 Calamba, Laguna Branch P-3423 NYK Auto Logistics Philippines Inc 20,476.95 Home Office P-3424 NYK Auto Logistics Philippines Inc 17,589.51 Home Office P-3425 NYK Auto LoQistics Philippines Inc 656.48 Home Office P-3426 NYK Auto Logistics Philippines Inc 17,801.41 Home Office P-3427 NYK Auto Logistics Philippines Inc 127.93 Home Office P-3428 NYK Auto Logistics Philippines Inc - 137.61 Home Office P-3429 Pasig First Capitol R~e,"a,~lt~yC:-'o"-r"--p~~~~~~~~t---~~-1',2-6'5-.:0"0?:"'H:o"m:-e-JO-f-fi'ce-'-==~=~~~~---1 P-3430 Pasig First Capitol Realty Corp 1,265.00 Home Office 1---P'P----_-33~44-"3-36'-1--t-'-P_S-aa,_n,sing"''o-'F-'Pi,_,hrs"i-lti=pCpainpeitosI:-RM:'ea"a'n"'Iut"y:fa-C'c"'ot"'urrp"'in-lQ---=C-o-,p-co-r-at:cio_r_l~~~t--~--c-=-""1'31-,,'92'86-45'..-50"50'"--CH1'ao-vm'ite:e'O=B"frf'aic-n-ec'h?=.,---~~~~--j P-3437 Sanna Philippines ManufacturinQ Corporation 18,611.14 Cavite Branch f-'-P--'-3=-4'-'3'-'8'--t-=S"'a'-'n'-'n"-o_,_P_...hi.li�eir:l_es Man ufactu rinQ Corporation 15,512.49 Cavite Branch _____.E-3439 Sanna Phili02ines Manufacturing Corporation 17,300.69 Cavite Branch P-3440 San no Phi Iip()in e3 Man ufactu ri n~g~C=-o=-r~p_-o'-'ra'-'t"'io"'n~~----t-~1~'4-",9'=2-'7-.'4--8"'--fC-'=a"v-"it'e-- Branch P-3441 San no Philipp_ines Manufacturing Corporation 16 534.07 Cavite Branch I I-'-P.::--3"4::4,_,2,__t-'::S>oa"'n.,n"=o_,_P-'-'hi!l2�ines Manufactu ring Corpora!ion 385.68 Cavite Branch f-'--P--'-3'-'4~4_-3---t--'S"-'o'-"li"'d--'C'-'e"-m"'ent Corp'---~--~~~~--,-~~~~--t-~----8'7~,224.55 Home Office I I Southern Asia-Pacific Division Corp of General 1-'--P--'-3""4"'424--;_,C"'o"nference of Seventh-Day Adventists 609.35 Cavite Branch Southern Asia-Pacific Division Corp of General 1-'-P__,-3"-4'-4'-'5'-----1---"C"'o"-'n"-'fe_,r'-e"-nc"'e of Seventh-Day Adventists 490.43 Cavite Branch Southern Asia-Pacific Division Corp of General P-3446 Conierence of Seventh_-Day Adven.-"t"'is,"ts"---~- -~~---ti---~--5-07-.-35===C-a-vtit-e"B-ra'n=c=h===~~--~- P-3447 I Southern Asia-Pacific Division Corp of General Conference of Seventh_:Da_y}._,d,_,v,..e,.,n"ti-e:st,_,s~~~~~-+~~~--'6"'0,._.9'c.-.:6__:_1_+ Cavite Branch ----jj Southern Asia-Pacific Division Corp of General 1---'--P--'-3'-'4-=-4.,_8_+--'C"-'o'-'nferenee of seven th-Day_,A_o:de_:v,_,e_,n,.,ti,_,st._s'--~~~~--+~--~-;"'56,-6"-.,-3_,_1-+.._Cc,a"-v-'-'ite=-..=B:cra~cn'-"c"'h'--~~- Southern Asia-Pacific Division Corp of General '_j P-3449 Conference of Seventh-Day Adventists � 585.09 Cavite Branch ~ Southern Asia-Pacific Division Corp of General i P-3450 Conference of Seventh-Day Adventists 516.30 Cavite Branch ----j f-~~~---,~~- Fourth Quarter _J P-3451 Alteza Realty C_Qrp___~~--~--~~~~~~j--~~-'-1,,2,_,6_-5'-0'.'-'0'-+--'H_,_o=-m=e-'0'-'ff'-'cic=-e"---~--~ P-3452 Alteza Reaity__g-=o-'-'rp..__~~--~~~~~~~~-+-~~-1'-',2"'6"-'5'-'-.0"'0=---'--'H_,_o,.,m=e_-O,_,ff"'ic'-'e'---~~- P-3453 Alteza Realty_C"-o"'r""p__ 1,265.00 Home Office ~- c---f'-3454 Bandai Na:nco Philij:l"-,p'-'i"-ne~,s"-''-'1'-'nco-.o�--~~~~~~~-+~~-"3"-5"'-,581.89 Batangas Branch r--'=-:;l455__ ~!!_dal Namco PJlil.l.e2ines, Inc. 33,528.13 Batangas Branch P-345~- Bandai NamcQ_Philij:lpin~s. Inc. 26,213.21 Batangas Branch P-3457 Bandai Namco Philij:lj)ices, Inc. 31,079.27 Batanoas Bra'-'nc,.,h"--~~~--J f----P-3458 Bandai Namco Philipoi�1es, Inc. 30,101.8G Batangas Branch I 1---l"-3459__ Bandai Namco Philippines Inc J 22,363.70 Batangas Branch --l P-3460 Brother Industries (Philippines) Inc. P-3461 EMD Technologi~s Philigpines, Inc. I 463,116.17 Batangas Branch 1,120.93 1 Calamba, L~na Brancq P-3462__EMD Technologies Philippines, Inc. ~. �170.47 Calamba, Laguna Branch____: P-3463 EMD Technologies Philippines, Inc. I 1,141.37 ~a_lamba, Laguna Branch -~ ___1"::_3464 __ __E_~ji_lndustci~Man~a Corp. I 87,509.70 Batanqas Branch , ! P-3465 __ Fuji Industries Manila Corp,__________~~-+~-c1~0_-0,,-=0=2-"-3'-'.5_-5__ ~_tangas Branch -~ ['P-3466 _J_~i__lrl_dustnes Manila Co'!'c_ 154,089.41 Batangas Branch : I P-3467 liM Digital Phili�Eines, 'nc. 197,607.66 Batangas Branch I P-3468 __l 131311.2. Quarry_l_l._6_g_r~~~Or!Joration 24 15 CHaovm1teeO�Bffr1;c;e-;;;;;;-------~ 2,540,973.33 P-3469--I�JAE PHiLS INC _ P-3470 Katolec Philippines c::;orporation~--~~---- 44,009.73_-r-,sta Rosa Laguna Braner:] ---+-- 119,579.75 Home Off!~--~-- I P-3471 Nanox Pll_ilippin_~lnc. �.. ==--+-'N.o:anox Philippines, !nc.- __ 3,696.00 Home Office -j ',-'-.::'=-"---j-'-"'Nanox Philippines, InC. ------r-~-~1c2,~7'-',2~0'-'5-'-'.0~~<?me Office _ _ _I J !'-lanox Philippines, I-nc. -----+~~~9,_,7,437.24 Home Office -"---.L-'-'N_:o~nox Phi!ippln-"e"'s,_,l'-'nco-.o�----~- --~~--~~~- 85,889.54 Home Office ___ ~___j

.SEPARATE OPINION. Service Resources, Inc. vs. Commissioner of Internal Revenue CTA Case No. 10503 P-3476 Nanox Philippines, Inc. 76,337.10 Home Office P-3477 Nanox Philippines, Inc. 792.00 Home Office P-3478 Nanox Philippines, Inc. Home Office P-3479 NYK Auto Logistics Philippines Inc 93,829.30 Home Office P-3480 NYK Auto Logistics Philippines Inc 16,943.36 Home Office P-3481 NYK Auto Logistics Philippines Inc Home Office P-3482 NYK Auto Logistics Philippines Inc 262.27 Home Office P-3483 NYK Auto Logistics Philippines Inc 18,363.19 Home Office P-3484 NYK Auto Logistics Phili{JQines Inc 21,563.07 Home Office P-3485 NYK Auto Logistics Philippines Inc Home Office P-3486 NYK Auto Logistics Philippines Inc 250.80 Home Office P-3487 NYK Auto Lo~istics Philippines Inc 246.18 Home Office P-3488 NYK Auto Lo~istics Philippines Inc 23,23146 Home Office P-3489 Pasi~ First Capitol Realty Corp Home Office P-3490 Pasi~ First Capitol Realty Corp 5744 Home Office P-3491 Pasi~ First Capitol Realty Corp 19,141.66 Home Office P-3498 San no Philippines Manufacturinq Corporation Cavite Branch P-3499 San no Philip[lines Manufacturing Corporation 11440 Cavite Branch P-3500 Sanna Philippines Manufacturing Corporation 1,265.00 Cavite Branch P-3501 Sanna Philippines Manufacturinq Corporation 1,265.00 Cavite Branch P-3502 Sanna Philip[lines Manufacturing Corporation 1,265.00 Cavite Branch P-3503 San no Philippines Manufacturing Corporation 16,04723 Cavite Branch P-3504 Solid Cement Corp. 19,094.57 Home Office 14,516.99 P-3505 Southern Asia-Pacific Division Corp of General 17,258.59 Conference of Seventh-Day Adventists 15,24648 P-3506 11,66840 Southern Asia-Pacific Division Corp of General 2,641.92 P-3507 Conference of Seventh-Day Adventists 49745 Cavite Branch P-3508 Southern Asia-Pacific Division Corp of General Conference of Seventh-Day Adventists 545.53 Cavite Branch P-3509 P-3510 Southern Asia-Pacific Division Corp of General 1,285.68 Cavite Branch Total Conference of Seventh-Day Adventists 498.14 Cavite Branch Southern Asia-Pacific Division Corp of General Conference of Seventh-Day Adventists 547.12 Cavite Branch Victon' Christian Fellowship of Los Banos, Inc. 943.62 Home Office 17,851 ,271.63 ALL TOLD, VOTE to DENY respondent's Motion for Reconsideration (on the Decision dated July 5, 2024) solely based on the discussion above. Presiding Justice