ERNEST LOGISTICS CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY THIRD DIVISION ERNEST LOGISTICS CTA CASE NO. 11973 CORPORATION Petitioner, Members: -versus- MANAllAN, Chairperson, REYES-FAJARDO, and ANGELES, JJ. COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. __,A_,'"U""'-G='--""--......,___,?.~~-- x------------------- ---- --- -~-- ~�~t: ~;q. -~ .: ---- -x RESOLUTION On June 4, 2025, petitioner filed a Petition for Review dated June 4, 2025 seeking the nullification of the respondent Commissioner of Internal Revenue's Decision on the Final Decision on Disputed Assessment (FDDA) dated January 6, 2025, and the Warrant of Distraint and/or Levy (WDL) dated May 22, 2025. However, petitioner electronically filed the PDF copy of the Petition on June 8, 2025 which was more than twenty-four (24) hours from the filing of the paper copies of said Petition. As such, the Petition for Review is deemed not filed due to petitioner's failure to electronically file the PDF copy of the said Petition within twenty-four (24) hours from the filing of the paper copies in accordance with Court of Tax Appeals En Bane Resolution No. 8-2024. In addition, the Court observes that the Secretary's Certificate dated June 3, 2025, and the Verification and Certificate of Non-Forum Shopping dated June 4, 2025, are both defective for lack of competent proof of affiant's identity as required under the 2004 Rules on Notarial Practice. WHEREFORE, in view of the foregoing, the Petition for Review is deemed not filed.

RESOLUTION CTA CASE NO. 11973 Page 2 of2 SO ORDERED. ~-7= CATHERINE T. MANAHAN Associate Justice ~ Qwr r. ~ ~Fal~ MARIAN JW F. Iffi%s-F'AJARDO Associate Justice HENRY~/):;GELES Associate Justice