COMMISSIONER OF INTERNAL REVENUE v. MA. ERLINDA T. ONG, Doing Business Under the Name and Style Maranatha Sales Distributor, Duly Represented herein by her Attorney-in-fact, Ms. Ria Sablon,

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTA EB NO. 2978 REVENUE, (CTA Case No. 10265) Petitioner, Present: RINGPIS-LIBAN, P.J, -versus- BACORRO-VILLENA, MODESTO-SAN PEDRO, REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, and MA. ERLINDA T. ONG, Doing ANGELES, JJ Business Under the Name and Style "Maranatha Sales Distributor, Duly Promulgated: represented herein by her Attorney-in- MAY 26 2~:> fact, Ms. Ria A. Sablon Respondent. ,~r~: ~~-.s-Q .,..,..., � X ---------------------------------------------------------------------------------------- X RESOLUTION MODESTO-SAN PEDRO, J.: For the Court' s resolution is petitioner's Motion for Reconsideration (Re: Decision promulgated on 08 January 2026), filed on January 26, 2026, with respondent's Comment/Opposition to the Motion for Reconsideration, filed on February 20, 2026, assailing, this Court's Decision, dated January 8, 2026, which denied the instant Petition for Review. A quick comparison ofthe Motion for Reconsideration with the Petition for Review reveals that the former is a near-verbatim copy of the latter, sans the argument that the Court in Division erred in enjoining petitioner from collecting the subject amount. All arguments raised in the Motion have thus already been discussed and refuted in the Assailed Decision. There is thus no~

RESOU TIO'< CT A FJJ i\o. 2978 (CrA Case 1\o_ 1026:') Page2of2 need to repeat such discussions here, 1 and the Motion should simply be denied. ACCORDINGLY, petitioner's Motion for Reconsideration (Re: Decision promulgated on 08 Januwy 2026), filed on January 26, 2026, is hereby DENIED for lack of merit. The Decision, dated January 8, 2026, is AFFIRMED. SO ORDERED. ,___ WE CONCUR: ~.~ MA. BELEN M. RINGPIS-LIBAN Presiding Justice JEANMA _ac�~. ~~ CORRO-VILLENA CiH LEAVE MARIAN IVY F. REYES-FAJARDO Associate Justice -an LA~l~r.iYfr~A~liCAUI-.;'AiVID Associate Justice co~t"~R2~Es Associate Justice HENRYJ)!jNGELES Associate Justice See Roctue r. Cummis.Yion on E/euiun, G.R. No. I88456 (Resolution). February I0, 201 0; see also Shangri-La lnternathmal Hotel Afanagement. Ltd. ,._ Derelopers Group ~/'Companies, Inc., G.R. No. 159938 (Resolution). January 22. 2007: see also Ortigas and Company Limited Parlnership r. l'elasco. G.R. Nos. 109645 & 112564 (Resolution). March 4. 1996.