TRAVELLERS INTERNATIONAL HOTEL GROUP, INC. v. COMMISSIONER OF INTERNAL REVENUE

Resolution CTA Case No. 9769 Page 2 of2 Calendar Year 2012, and the Formal Letter of Demand, with attached Details of Discrepancies and Assessment Notice, dated June 13, 2017, are hereby DECLARED VOID, CANCELLED and WITHDRAWN. SO ORDERED." In support thereof, respondent argues that: (i) petitioner is not exempt from income tax on revenues from gaming operations as the tax exemptions granted to the Philippine Gaming Corporation (PAGCOR) under Presidential Decree No. 1869 does not extend to licensees of PAGCOR's franchise; (ii) the Formal Letter of Demand dated June 13, 2017 states the facts and the law on which the assessment was based; hence, the same is valid; and, (iii) petitioner failed to prove the impropriety of the assessment. Acting on respondent's Motion, the Court notes that no new substantial arguments have been adduced to warrant the reconsideration sought. Respondent merely raised matters which the Court has thoroughly passed upon in the assailed Decision. Accordingly, the Court finds no cogent reason to reverse or modify the assailed Decision. WHEREFORE, in light of the foregoing, respondent's "Motion for Reconsideration [Decision dated September 14 [sic], 2020]" posted on September 30, 2020 is hereby DENIED for lack of merit. SO ORDERED. Presiding Justice /CONCUR: ~�/)~ CATHERINE{ MANAHAN Associate Justice