UNISYS PUBLIC SECTOR SERVICES CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY THIRD DIVISION UNISYS PUBLIC SECTOR C.T .A. CASE NO. 8293 SERVICES CORPORATION, Members : Petitioner, BAUTISTA, Chairperson ; -versus- FABON -VICTORINO, and RINGPIS LIBAN , 2L. COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. SEP 2 2 2015 x- - - - - - - - - - - - - - - - - - - - - - - - - ~ - 1 - / - :-L---{-() - q - �- - - ..... - - - - - -x DECISION This is a claim for refund or issuance of a tax credit certificate (TCC) in the amount of Seventy- Six Million Ninety-One Thousand Eighty-Seven Pesos and 98/100 (P76,091,087. 98), allegedly representing erroneously paid or illegally collected value-added tax (VAT) for calendar year (CY) 2009 and for the three (3) quarters of CY 2010 filed by petitioner Unisys Public Sector Services Corporation . THE FACTS Petitioner Unisys Public Sector Services Corporation is a domestic corporation with address at Level 9 One Cyberpod, Eton Centris Station, EDSA corner Quezon Avenue, Quezon City. It was incorporated on July 14, 1994 with the primary / purpose as follows 1: ~ "To create, manufacture, process, assemble, fabricate, develop, supply, license, 1 Exhibits " A" to "A- 2".

Decision C.T.A. CASE NO. 8293 lease (without engaging in financial leasing), sell at wholesale (for cash or on credit), barter, exchange, trade, make advances upon, import or otherwise acquire, distribute, integrate, market, upgrade or modify computer hardware, computer systems software programs, applications, components, devices and supplies, as well as to provide support, training and Consultancy services in the use and application of these products; to do any and all acts and things in relation to, arising out of and incidental to the creation, manufacturing, processing, assembly, fabrication, development, supply, licensing, leasing, sale, barter, exchange, trade, importation, acquisition, distribution, marketing, upgrading or modification of the aforementioned products, including but not limited to the sale, installation and maintenance of computer hardware, computer systems software programs, applications, components, devices and supplies, as well as to supply, install, maintain and provide management, operational, and technical expertise and other advisory and consultation services." Petitioner is a registered VAT taxpayer with Tax Identification Number (TIN) 003-933-453-000 issued by the Bureau of Internal Revenue (BIR). 2 Respondent, on the other hand, is the Commissioner of Internal Revenue (CIR), with the authority to act on claims for refund or tax credit of erroneously or excessively paid taxes. She holds office at the BIR National Office Building, BIR Road, Diliman, Quezon City. On December 23, 1999, Unisys Australia Limited (UAL), (Philippine Branch) entered into a contract for an estimated period of twelve (12) years with the National Statistics Office (NSO), a government agency responsible for the collection, compilation, classification, production, publication and / 2 Exhibit "B".

Decision C.T.A. CASE NO. 8293 dissemination of general-purpose statistics and civil registry data. The Civil Registry System Information Technology Project (CRS-ITP) Contract3 provides, among others, that UAL would be responsible for the design, development, construction, installation, testing and commissioning of NSO's Civil Registry System-Information Technology (CRS- IT). On July 1, 2001, UAL and petitioner, with the consent of NSO, executed an Assignment and Assumption Agreement4 (Agreement) by virtue of which UAL unconditionally and irrevocably assigned and transferred to petitioner all its rights, title, benefits, privileges and interests and obligations, undertakings, covenants, liabilities and indebtedness, including any obligation, undertaking, covenant, liability or indebtedness that may have accrued and have not been fully performed or paid as of the date of the Assignment. For the four quarters of CY 2009 and the succeeding three quarters of CY 2010, petitioner generated gross sales in the amount of P1,382,319,932.81 5� Petitioner subjected to and withheld five percent (5%) final VAT on its gross sales to NSO pursuant to Section 114{C) of the National Internal Revenue Code (NIRC) of 1997, as amended. Petitioner filed its VAT Returns for the four quarters of CY 2009 and for the succeeding three quarters of CY 2010 and paid the total amount of P148,031,890.38 on the following dates. Quarter Date of Filing of VAT Return Exhibit (CY 2009) and payment of VAT First April 24, 2009 "S" and "S-1" First (amended) January 19, 2011 "F" and "F-1" Second July 23, 2009 "T" and "T-1" Second (amended) January 20, 2011 "G" and "G-1" Third October 23, 2009 "U" and "U-1" Third (amended) January 20, 2011 / "H" and "H-1" 3 Exhibit "N". 4 Exhibit "0". 5 Exhibits "C"I "D"I "E"I "F"I "G"I "H" and "I"�

Decision January 25, 2009 "V" and "V-1" C.T.A. CASE NO. 8293 January 20, 2011 "I" and "I-1" Fourth Fourth (amended) Quarter Date of Filing of VAT Return Exhibit (CY 2010) and payment of VAT April 26 2010 "W" and "W-1" First6 January 20, 2011 "J" and "J-1" First (amended)7 July 26, 2010 "X" and "X-1" January 20, 2011 "K" and "K-1" SecondH October 20, 2010 "Y" and "Y-1" January 20 2011 "L" and "L-1" Second (amended)" Third 1u Third (amended) 11 Subsequently, petitioner discovered that it erroneously paid VAT to the BIR when it used its actual accumulated input VAT for the four quarters of the CY 2009 and the succeeding three quarters of CY 2010, instead of the seven percent (7%) standard input VAT in computing the net VAT payable. As a consequence, it overpaid VAT for the cited period in the total amount of P76,091,087.98. On February 11, 2011, petitioner filed with the BIR Large Taxpayers Regular Audit Division III a claim for refund or issuance of a TCC for the alleged erroneously overpaid VAT of P76,091,087.98. 12 On May 30, 2011, petitioner filed the instant Petition for Review claiming inaction on the part of respondent on its application for refund and to suspend the running of the two-year prescriptive period under the law. 13 On July 12, 2011, respondent filed her Answer14 stating that petitioner's claim is subject to routinary examination. In any event, there is no showing that petitioner submitted complete documents pursuant to Revenue Memorandum Order (RMO) No. 53-98 justifying denial of the application by inaction. Finally, a claim for refund is construed strictly against the claimant for it partakes of the nature of an 6 Exhibit "D". / 7 Exhibit "D". 8 Exhibit "E". 9 Exhibit "F". 10 Exhibit "G". 11 Exhibit "G". 12 Exhibit "C". 13 Docket, pp. 1-12. 14 Docket, pp. 100-108.

Decision C.T.A. CASE NO. 8293 exemption from taxation 15 and as such, it is looked upon with disfavor16� After the pre-trial conference, the Pre-Trial Order17 dated September 15, 2011 was issued based on the parties' Joint Stipulation of Facts and Issues18 � During the trial, petitioner presented witnesses Jennifer G. Glinoga, Veronica Joy R. Catajoy, and Annalyn B. Artuz. Petitioner's Finance Manager since January 2007, Jennifer G. Glinoga, by way of Judicial Affidavit, 19 testified that she oversees all matters relating to petitioner's tax reporting and regulatory compliance. Petitioner is engaged in the business of licensing and modifying computer hardware, computer system software programs, application, components, devices and supplies, as well as providing support, training and consultancy services in the use and application of said products20 . It is registered with the BIR with Certificate of Registration No. 8RC000001969321 � On December 23, 1999, NSO and UAL executed the CRS-ITP Contract, 22 which petitioner assumed on July 1, 2001, via the Assignment and Assumption Agreement23 � Based on the two (2) agreements, petitioner shall be responsible for the design, development, construction, installation, testing and commissioning of NSO's CRS-IT. NSO shall pay petitioner a percentage of the revenues generated by NSO for the use of the Project's technology in rendering services to the public, which includes, authentication, certification, and issuance of Certificate of Live Birth, Certificate of Marriage, Certificate of No- marriage, and other civil registry data. For the four quarters of CY 2009 and the succeeding/ 15 Commissioner of Internal Revenue vs. Ledesma, 31 SCRA 95. 16 Western Minolco Corp. vs. Commissioner of Internal Revenue, 124 SCRA 1211. 17 Docket, pp. 155-160. 18 Docket, pp. 131-133. 19 Exhibits "EEE" and "EEE-1". 20 Exhibits "A" to "A-2". 21 Exhibit "B". 22 Exhibit "N". 23 Exhibit "0".

Decision C.T.A. CASE NO. 8293 three quarters of CY 2010, petitioner generated a total gross sales of P1,327,843,870.0324, which were subjected to the 5% final VAT of P66,392,193.50 25 deducted and withheld by , NSO pursuant to Section 114(C) of the NIRC of 1997, as amended. However, in computing for its output VAT liability, petitioner erroneously credited the actual amount of its input VAT accumulated for the period, instead of the 7% standard input VAT prescribed for payments received from the Government through the NSO, although the actual accumulated input VAT was lower than the 7% standard input VAT on that period. Consequently, petitioner erroneously paid P76,091,087.98 VAT. Petitioner filed its VAT returns26 with the BIR through the Electronic Filing and Payment System (EFPS) 27 and paid the corresponding VAT of P148,031,890.38, inclusive of the erroneously paid VAT, for the four quarters of CY 2009 and the succeeding three quarters of CY 2010. On February 11, 2011, petitioner filed an administrative claim for refund/TCC28 which remains pending with respondent. Hence, the filing of the instant petition on May 30, 2011. In her Judicial Affidavit29, witness Veronica Joy R. Catajoy declared that she worked with Isla Lipana & Co., which services as External Tax Consultant was secured by petitioner. In connection thereto, she handled petitioner's tax concerns under the supervision of Mary Assumption S. Bautista-villareal. She and her team reviewed and amended petitioner's VAT filings for the four quarters of CY 2009 and the succeeding three quarters of CY 2010, and assisted petitioner in the filing of its administrative claim for refund with the BIR. 24 Exhibits "GG-2", "HH-2", "11-2", "JJ-2", "KK-2", "LL-2", "MM-2", "NN-2", "00-2", "PP-2", "QQ-2", "RR-2", "SS-2", "TT-2", "UU-2", "VV-2", "WW-2", "XX-2", "YY-2", "ZZ-2" and "AAA-2". 25 Exhibits "GG", "HH", "II", "JJ", "KK", "LL", "MM", "NN", "00", "PP", "QQ", "RR", "55", "TT", "UU, "W", "WW", "XX", "YY" and ZZ". / 26 Exhibits "F", "F-1", "G", "G-1", "H", "H-1", "I", "1-1", "J", "J-1", "K", "K-1", "L", "L- 1", "5", "S-1", "T", "T-1", "U", "U-1", "V", "V-1", "W", "W-1", "X", "X-1", "Y" and "Y- 1II' 27 Exhibits "5-1", "T-1", ''U-1", "V-1", "W-1", "X-1" and "Y-1". 28 Exhibits "C" to " C - 2 1 and "M" to "M-2". ' 29 Exhibits "HHHH" and "HHHH-1".

Decision C.T.A. CASE NO. 8293 Per their review, petitioner has an existing build, operate and transfer (BOT) contract with the NSO for the design, development, construction, installation, testing and commissioning of NSO's CRS-IT for which petitioner receives a percentage of the revenues generated from it. For the four quarters of CY 2009 and the succeeding three quarters of CY 2010, petitioner collected a total of P1,327,843,870.03 for its sale of services to NSO pursuant to the BOT contract, which was subjected to 12% VAT. The total output VAT liabilities incurred by petitioner from its sales to NSO were categorically segregated from its total sales. As a government entity, NSO withheld a 5% final VAT of P66,392,193.48 from its payments to petitioner which represents the net VAT payable by petitioner, while the remaining 7% effectively accounts for the standard input VAT, in lieu of the actual input VAT directly attributable or ratably apportioned to such sales. In computing its VAT liability for the covered period, petitioner erroneously deducted its actual input VAT of P17,846,501.25, instead of the 7% standard input tax as provided under Section 114(C) of the NIRC of 1997, as amended, and as implemented by Section 4.114-2 of Revenue Regulations No. 16-2005, from its total output VAT liabilities of P165,878,391.96. Thus, petitioner erroneously paid a total VAT of P148,031,890.38. In connection with the VAT overpayment, her team revalidated the accuracy and correctness of petitioner's original computations and discovered that petitioner erroneously credited the actual amount of its input VAT accumulated for the period, instead of the 7% standard input VAT which is prescribed for payments received from the government. Hence, petitioner overpaid its VAT liabilities in the total amount of P76,091,087.98. To arrive at the net VAT payable, the amount of P92,949,070.91, representing petitioner's 7% standard input VAT, was deducted since the majority of petitioner's services were rendered to NSO, hence, the 7% standard input VAT shall be in lieu of petitioner's actual input VAT directly / attributable or ratably apportioned to its total sales for the ~

Decision C.T.A. CASE NO. 8293 covered period. The 7% standard input VAT was higher than the actual input VAT attributable to its sales to NSO for the covered period. The difference was reported by petitioner as part of its "Non-operating & Taxable Other Income" in its Amended Annual Income Tax Return for CY 2009 and Annual Income Tax Return for CY 201030� The difference in the input VAT used by petitioner and the input tax in the amended VAT Returns pertains to the withholding VAT remitted by petitioner from its royalty payments to Unisys Corporation31, a non-resident corporation. Petitioner paid VAT in the total amount of P148,031,890.38 for the four quarters of CY 2009 and the succeeding three quarters of CY 2010. On February 11, 2011, petitioner, with their assistance, filed its administrative claim for refund/TCC for its erroneous overpayments. Independent Certified Public Accountant (ICPA) Annalyn B. Artuz also executed a Judicial Affidavit32 declaring that petitioner's overpayment of VAT was due to its use of actual input VAT as deduction against output VAT in computing for the net VAT payable in its originally filed VAT Returns instead of the 7% standard input VAT. Petitioner's total actual VAT payments consists of actual VAT payments upon filing of the original VAT Returns amounting to P81,639,696.87 and 5% final VAT withheld by NSO amounting to P66,392,193.50 for the four quarters of CY 2009 and the succeeding three quarters of CY 2010. Based on her examination of pertinent documents, petitioner is entitled to its claim for refund pertaining to its erroneous overpayment of VAT in the total amount of P76,091,087.98 for the four quarters of CY 2009 and the / succeeding three quarters of CY 2010. ~ 30 Exhibits "E" and "Q". 31 Exhibits "BBB", "CCC" and "DDD". 32 Exhibits "FFFFFFF" and "FFFFFFF-1 ".

Decision C.T.A. CASE NO. 8293 The ICPA clarified that petitioner's claim for refund pertains to its VAT payments in excess of the 5% final VAT withheld by NSO for its sales to the government. After petitioner rested33, respondent presented Revenue Officers (ROs) Melinda Lim and Maria Nimfa P. Saga. RO Melinda G. Lim, stated in her Judicial Affidavit34, that she is currently with the Large Taxpayers Regular Audit Division III of the BIR. She learned about the case through petitioner's request for refund filed on February 11, 2011 pertaining to its alleged VAT overpayment amounting to P40,606,843.59 for CY 2009. On July 1, 2011, Letter of Authority No. LOA-126-2011- 00000016 was issued against petitioner. Thereafter, three notices were sent to it, namely: 1) The First Notice/Initial Data Request with attachmene5 ; 2) the Second Notice 1 Data Request with attachment36; and 3) the Third and Final Notice with attachmene7, which she and her Division Chief Lindagrace B. Sagum signed 38 � Despite receipt of all the Notices39, petitioner only partially complied. In her Memorandum dated February 26, 2012 approved by OIC-Assistant Commissioner of the Large Taxpayers Service, Alfredo V. Misajon40 , she recommended the denial of petitioner's entire claim for refund on the following grounds: 1) the claim lacks legal basis; 2) petitioner has no personality to claim refund; and 3) submission of incomplete records. In a Letter dated February 26, 201241, petitioner was informed of the denial of its claim42 � RO Lim affirmed that petitioner's claim for refund was due to its erroneous computation of its net VAT payable./ 33 Docket, pp. 720-722. 34 Exhibits "13" and "13-A". 35 Exhibit "2". 36 Exhibit "3". 37 Exhibit "4". 38 Exhibits "2-A", "3-A" and "4-A". 39 Exhibits "2-B", "3-B' and "4-B". 40 Exhibits "5-A" and "5-B". 41 Exhibits "6" and "6-A". 42 Exhibit "6-B".

Decision C.T.A. CASE NO. 8293 However, VAT refunds are only allowed in three instances, i.e., in relation to zero-rated sales, purchases or dissolution of business. In her Judicial Affidavit43, RO Nimfa P. Saga, assigned at the BIR's Large Taxpayers Excise Audit Division 2, corroborated the foregoing declaration and added that she denied petitioner's claim for refund because based on her review of the documents submitted, it has no legal basis. Further, petitioner only submitted the Assignment and Assumption Agreement and the Civil Registry and Information Technology Project. Moreover, VAT refund is allowed only in three instances, namely, zero-rated, fixation and dissolution of business and she does not know whether overpayment of tax is one of the basis for refund. After submission of the parties' respective memoranda, the case was submitted for decision on September 24, 2014. 44 THE ISSUES The following issues are for the resolution of the Court: 45 1. Whether petitioner erroneously computed VAT liability for the four quarters of CY 2009 and the succeeding three quarters of CY 2010; 2. Whether petitioner overpaid its VAT liabilities for the four quarters of CY 2009 and the first three quarters of CY 2010; 3. Whether petitioner is entitled to a tax / refund/TCC in the amount of P76,091,087. 98, representing erroneous VAT payments for CY 2009 and for the 43 Exhibits "14" and "14-A". 44 Docket, p. 914. 45 Stipulation of Issues, JSFI, docket, pp. 132-133.

Decision C.T.A. CASE NO. 8293 succeeding three quarters of CY 2010; and 4. Whether petitioner complied with all the evidentiary requirements in its administrative claim for refund/TCC. DISCUSSION/RULING The foregoing issues may be simplified as follows: Whether petitioner is entitled to a refund/TCC in the amount of P76,091,087.98, allegedly representing erroneous VAT payments for CY 2009 and for the succeeding three quarters of CY 2010. The Court must first determine the timeliness of the filing of the claim. Under Sections 204(C) and 229 of the NIRC of 1997, as amended, both the administrative claim for refund/TCC filed with the BIR and the subsequent appeal to the CTA must be filed within two years from the date of payment of tax. 46 46 "SEC.204. Authority of the Commissioner to Compromise, Abate and Refund or Credit Taxes. - The Commissioner may - XXX XXX XXX (C) Credit or refund taxes erroneously or illegally received or penalties imposed without authority, refund the value of internal revenue stamps when they are returned in good condition by the purchaser, and, in his discretion, redeem or change unused stamps that have been rendered unfit for use and refund their value upon proof of destruction. No credit or refund of taxes or penalties shall be allowed unless the taxpayer files in writing with the Commissioner a claim for credit or refund within two (2) years after the payment of the tax or penalty: Provided, however, That a return filed showing an overpayment shall be considered as a written claim for credit or refund." / "SEC. 229. Recovery of Tax Erroneously or Illegally Collected. - No suit or proceeding shall be maintained in any court for the recovery of any national internal revenue tax hereafter alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum alleged to have been excessively or in any manner wrongfully collected, until a claim for refund or credit has been duly filed with the Commissioner;

Decision C.T.A. CASE NO. 8293 Applying the cited provisions, the prescriptive date for filing both the administrative and the judicial claims shall be as follows: CY 2009 Exhibit Date of Last Day to File 1st Quarter Pavment its Claim 2"d0uarter z Aoril 27. 2009 Aoril 27. 2011 3rd Quarter AA July 24. 2009 July 25. 201147 October 26, 4th Quarter BB October 26. 2011 CY 2010 2009 cc January 25, January 25, 2012 1stouarter 2"d0uarter 2010 Aoril 26. 2012 July 26, 2012 3rd Quarter DD Aoril 26. 2010 October 22. 2012 EE July 26. 2010 FF October 22, 2010 The record shows that petitioner filed its Letter Request48 for refund/TCC before the BIR on February 11, 2011 and sought judicial intervention through its Petition for Review with the Court of Tax Appeals on May 30, 2011. Clearly, petitioner seasonably filed its claim for VAT refund in the administrative level. The same is however untrue insofar as its judicial claim for VAT refund for the first quarter of CY 2009 is concerned on the ground that it has already prescribed. Thus, the Court shall determine petitioner's entitlement to tax refund or issuance of tax credit certificate only for the claims pertaining to the last three quarters of CY 2009 and the succeeding three quarters of CY 2010. Petitioner's original Quarterly VAT Returns for CY 2009 and the first three quarters of CY 2010 disclosed the following information: but such suit or proceeding may be maintained, whether or not such tax, penalty, or sum has been paid under protest or duress. In any case, no such suit or proceeding shall be filed after the expiration of two (2) years from the date of payment of the tax or penalty regardless of any supervening cause that may arise after payment: Provided, however, That the Commissioner may, even without claim therefor, refund or credit any tax, where on the face of / the return upon which payment was made, such payment appears .../ clearly to have been erroneously paid." (Emphasis supplied) 47 July 24, 2011 fell on a Sunday 48 Exhibit "C"", docket, pp. 335-339

Decision C.T.A. CASE NO. 8293 CY 2009 1"Qtr"� 2"" Qtr"0 3"' Qtr"' 4'" Qtr"' Total p 746 290 819.70 Vatable Sales/Receipt- P746,290,819.70 Private p 169 207 521.99 p 230 575 686.69 p 176 524 836.42 p 169 982 774.60 Total Sales/Receipts P169 201 521.99 P230 575 686.69 1'176,524 836.42 1'169 982 774.60 Output Tax Due p 20 304 902.87 p 27 669 081.88 P21 182 980.45 P20 397 929.36 p 89 554 894.56 Less: Available Input Tax p 1 149 078.25 p 1 306 057.79 p 993 689.85 p 888 850.39 p 4 337 676.28 1 306 570.14 1 038 833.47 5 731 945.98 Domestic Purchase of 1 751 079.17 1 635 463.20 Goods Other than p 2 455 648.39 p 1 927 683.86 p 10 069 622.26 Caoital Goods P17 849 254.48 p 3 057 136.96 p 2 629 153.05 P18 470 245.50 p 79 485 272.30 Domestic Purchase of p 24,611 944.92 P18 553 827.40 SeJVices p 5 816 824.99 p 6 859 269.73 p 27 778 088.58 Total Available 8 041 761.12 p 8 212 575.45 p 6 889 418.41 8 156 538.70 35 766 690.53 Input Tax p 13 858 586.11 11 101 798.81 8 466 591.90 p 5 015 808.43 p 63 544 779.11 Net VAT Payable p 3.990.668.37 p 3.454.437.07 p 15.940.493.19 Less: Tax p 19 314 374.26 p 15 356 010.31 Credits/Pavments Monthly VAT p 5.297.570.66 p 3.197.817.09 Payments -previous 2 months Creditable VAT Withheld Total Tax Credits Tax Still Payable (OverDavmentl CY 2010 1st Qtr"3 2"� Qtr54 3"' qtr55 Total Vatable Sales/Receipt- Private p 187 070 899.88 ,. 245 346 806.60 p 203 611 436.63 ,. 636 029 143.11 P187,070,899.88 P245,346,806.60 P203,~11,436.63 P636,029,143.11 Total Sales/Receipts Output Tax Due p 22,448 507.92 p 29 441 616.64 p 24 433 372.47 p 6 323 497.03 Less: Available Input Tax Domestic Purchase of p 721 159.51 p 2 368 260.18 p 901 333.92 p 3 990 753.61 Goods Other than Capital Goods 1 302 859.74 1 071 899.80 1 411 365.84 3 786 125.38 Domestic Purchase of Services p 2 024,019.25 p 3 440159.98 p 2 312,699.76 p 7,776,878.99 Total Available Input p 20 424,488.67 p 26,001,456.66 p 22 120 672.71 p 68 546,618.04 Tax p 6L834 913.55 p 8 591 739.57 p 8 535 937.11 p 23 962 590.23 Net VAT Payable 8 982 999.98 11 841 523.27 9 800 979.69 30,625,502.94 Less: Tax Credits/Pa_yments p 15 817 913.53 p 20 433,262.84 p 18 336 916.80 p 54 588 093.17 Monthly VAT Payments- previous 2 months p 4 606,575.14 p 5 568193.82 p 3 783,755.91 p 13,958,524.87 Creditable VAT Withheld Total Tax Credits Tax Still Payable (Overpayment) In computing its output VAT liability, petitioner initially utilized its actual input VAT arising from domestic purchases of services and goods other than capital goods, with no / 49 Exhibit "5". 50 Exhibit "T". 51 Exhibit "U". 52 Exhibit "V". 53 Exhibit "W". 54 Exhibit "X". 55 Exhibit "Y".

Decision C.T.A. CASE NO. 8293 reported input VAT on services rendered by non-residents. Furthermore, no amount was reported for sales to government and for input tax on sales to government closed to expense (excess of standard input over actual input VAT). Realizing that it erroneously computed its output VAT liability when it failed to recognize and report its sales to government and the corresponding seven percent (7%) standard input VAT, petitioner subsequently filed its Amended Quarterly VAT Returns for CY 2009 and the succeeding three quarters of CY 2010, reflecting a total overpayment of P76,091,087.9956, as presented below: CY 2009 1"Qtr07 2"' Qt,.S� 3" Qt,.S� 4th Qtr00 Total Vatable Sales/Receipt- p 8 372 299.47 p 8 539 710.51 p 7 192 998.36 p 6 851 970.50 p 30 956 978.84 Private 160 835 222.52 222 035 976.18 169 331 838.06 163 130 774.10 715 333 810.86 Sale to Government P169 207 521.99 P230 S75 686.69 P176 524 836.42 P169 982 744.60 P746 290 789.70 Total Sales Outout Tax Due p 1 004 675.94 p 1 024 765.26 p ,. 863 159.80 . 3 714 837.46 Vatable Sales/ 822 236.46 p Receiot-Private Sale to Government 19 300 226.70 26 644 317.14 20 319 820.57 19 575 692.89 85 840 057.30 Total Outout Tax p 20,304,902.64 p 27 669,082.40 p 21 182,980.37 p 20 397 929.35 p 89 554,894.76 Less: Available lnout Tax p 1 149 078.25 p 1 306 057.79 p 993 689.85 p ,. 888 850.39 4 337 676.28 Domestic Purchases 1 306 570.14 5 731 945.98 of Goods Other than 1 751 079.17 1 635 463.20 1 038 833.47 4 526 392.23 Capital Goods - Domestic Purchase - 2 453 885.36 2 072 506.87 of Services p 2 455 648.39 8 924 321.38 p 3 057 136.96 p 5,083 038.41 p 4 000 190.73 p 14 596 014.49 Services Rendered by Non-residents p 11 379 969.77 12 598 606.95 6 977 312.87 7 580 210.35 36 080 451.55 Total Input Tax p 8 924 932.87 for the Current p 15 655 743.91 p 12 060 351.28 p 11 580 401.08 p 50 676 466.04 oeriod p 5 816 824.99 p 12,013 338.49 p 9 122 629.09 p 8 817 528.27 p 38 878 428.72 8 041 761.13 Add: Input Tax on p 8 212 575.45 p 6 889 418.41 p 6 859 269.73 p 27 778 088.58 Sale to Gov't closed 3 990 668.37 to expense p 17,849,254.49 11 101 798.81 8 466 591.90 8 156 538.71 35 766 690.55 Total Available Inout VAT , 5 297 570.66 , 3 197 817.09 3 454 437.07 ,. 15 940 493.19 24,611,944.92 18 470 245.51 Net VAT Payable p 18,553,827.40 !Y 79 485 272.3 Less: Tax Credlts/Pavments Monthly VAT payments-previous 2 months VAT withheld on Sales to Government VAT paid in return previously filed, if this is an amended return Total Tax Credits 56 P40,606,843.60 (CY 2009) plus P35,484,244.39 (CY 2010) 57 Exhibit "F". 58 Exhibit "G". 59 Exhibit "H". 60 Exhibit"!".

Decision C.T.A. CASE NO. 8293 Total Amount PC8 924,321.62} PC 12 598 606.43} PC9 431 198.31} PC9 652 717.241 PC40 606 843.601 Payable COveroavment} CY 2010 1'' Otr61 2"" Otr62 3"' Otr63 Total Vatable Sales/Receiot-Private p 7 410 900.09 p 8 516 341.05 p 7 591 842.80 p 23 519 083.94 Sale to Government Total Sales 179 659 999.79 236 830 465.55 196 019 593.83 612 510 059.17 p 187 070 899.88 p 245 346 806.60 p 203 611 436.63 p 636 029 143.11 Output Tax Due p 889 308.01 p 1 021 960.93 p 911 021.14 p 2 822 290.08 Vatable Sales/Receiot-Private 21 559 199.97 28 419 655.87 23 522 351.26 73 501 207.10 Sale to Government p 22 448 507.98 p 29 441 616.80 p 24 433 372.40 p 76 323 497.18 Total Outout Tax p 721 159.51 p 2 368 260.18 p 901 333.92 p 3 990 753.61 Less: Available Input Tax 1 302 859.74 1 071 899.80 1 411 365.84 3 786 125.38 Domestic Purchases of 2 671 055.90 2 671 055.90 Goods Other than Capital - - Goods Domestic Purchase of p 2 024 019.25 p 3 440 159.98 p 4 983 755.66 p 10 447 934.89 Services Services Rendered by Non- 10 632 363.20 13 257 385.52 8 923 439.90 32 813 188.62 residents p 12 656 382.45 p 16 697 545.50 p 13 907 195.56 p 43.261.123.51 Total Input Tax for the Current period p 9 792 125.53 p 12 744 071.30 p 10 526 176.84 p 33 062 373.67 Add: Input Tax on Sale to Gov't closed to exoense p 6 834 913.55 p 8 591 739.57 p 8 535 937.11 p 23 962 590.23 Total Available Input VAT 8 982 999.99 11 841 523.28 9 BOO 979.69 30 625 502.96 Net VAT Payable Less: Tax 4 606 575.14 5 568 193.82 3 783 755.91 13 958 524.87 Credits/Pavments Monthly VAT Payments - p 20 424 488.68 p 26 001 456.67 I' 22 120 672.71 p 68 546 618.06 previous 2 months VAT withheld on Sales to P(10,632,363.15} P(13,257,385.37} P( 11,594,495.87} P(35,484,244.39} Government VAT paid in return previously filed, if this is an amended return Total Tax Credits Total Amount Payable (Overpayment) Petitioner asserts that the VAT overpayment of P76,091,087.98 constitutes erroneously paid tax which can be claimed as tax refund/credit under Section 229 of the NIRC of 1997, as amended, to wit: "SEC. 229. Recovery of Tax Erroneously or Illegally Collected. - No suit or proceeding shall be maintained in any court for the recovery of any national internal revenue tax hereafter alleged to have been erroneously or illegally assessed or / collected, or of any penalty claimed to have been collected without authority, or of any sum alleged 61 Exhibit "J". 62 Exhibit "K". 63 Exhibit "L".

Decision C.T.A. CASE NO. 8293 to have been excessively or in any manner wrongfully collected, until a claim for refund or credit has been duly filed with the Commissioner; but such suit or proceeding may be maintained, whether or not such tax, penalty, or sum has been paid under protest or duress. In any case, no such suit or proceeding shall be filed after the expiration of two (2) years from the date of payment of the tax or penalty regardless of any supervening cause that may arise after payment: Provided, however, That the Commissioner may, even without claim therefor, refund or credit any tax, where on the face of the return upon which payment was made, such payment appears clearly to have been erroneously paid." Petitioner further asserts that being an entity predominantly engaged in providing services to government or any of its political subdivisions, instrumentalities or agencies, including government-owned or controlled corporations (GOCCs), the distinct rule in Section 4.114-2 of Revenue Regulations (RR) No. 16-05, as amended, specifically on the rules in computing the VAT payable for the covered period must be taken into account. 64 On these points, respondent counters that petitioner is claiming a refund based on an erroneous perception of the revenue issuances particularly Revenue Memorandum Circular (RMC) No. 62-05 and petitioner failed to follow the procedure indicated in RMC No. 62-05 that it should mandatorily close the input difference between the standard and actual VAT to cost or expense. Hence, it was only correct for petitioner to pay VAT by computing 12% output tax net of actual input tax and credits. 65 Respondent continues to say that based on the law and implementing regulations, the total output tax of 12% is still due from sales to government entities, 5% is output tax / v/' withheld by the government agency and 7% is still output 1 64 Par. 25, petitioner's Memorandum, docket, p. 903 65 Respondent's Memorandum, docket, p. 879

Decision C.T.A. CASE NO. 8293 tax but to be treated in a specific manner. For petitioner's failure to follow the procedure, it was correct that it paid the total output tax due as originally filed because in the regular scheme of the VAT computation, the total output tax less input tax (with proper documentation based on actual purchases) is equivalent to output tax due.66 Respondent's arguments are untenable. Section 4.114-2 of RR No. 16-05, as amended by RR No. 04-07, implementing Section 114(C) of the NIRC of 1997, as amended, mandates the withholding of 5% final VAT on government money payments. In addition, Q & A No. 31 of RMC No. 62-05 authorizes the application of the standard input tax of seven percent (7%) of the selling price/gross receipts attributable to government sales. Conversely stated, the allowable input tax for sales of goods and services to the government shall not exceed five percent (5%) of the selling price/gross receipts. If actual input tax exceeds five percent (5%) of gross payments, the excess shall form part of the seller's cost or expense. On the other hand, if actual input VAT is less than five (5%) of gross payments, the difference shall be closed to cost or expense of the seller. The five percent (5%) final VAT withholding rate shall represent the net VAT payable of the seller. The remaining seven percent (7%) effectively accounts for the standard input VAT for sales of goods or services to government or any of its political subdivisions, instrumentalities or agencies including GOCCs, in lieu of the actual input VAT directly attributable or ratably apportioned to such sales to the Government. Should actual input VAT exceed the standard input VAT of 7% of gross payments, the excess may form part of the sellers' expense or cost. Conversely, if actual input VAT is less than the standard input VAT of 7% of gross payment, the difference must be treated as taxable income. 67 66 Respondent's Memorandum, docket, pp. 880-881. 67 Revenue Memorandum Circular No. 29-05, Q & A No. 17.

Decision C.T.A. CASE NO. 8293 Therefore, petitioner's overpayment of VAT which arose from erroneous application of its actual accumulated input VAT for the four quarters of CY 2009 and the succeeding three quarters of CY 2010 instead of the seven percent (7%) standard input VAT shall be refundable as erroneously paid tax pursuant to Section 229 of the NIRC of 1997, as amended, if petitioner can establish that its actual accumulated input VAT attributable to its government sales was lower than the 7% standard input VAT. As stated however, only the VAT overpayment pertaining to the second quarter of 2009 up to the third quarter of 2010 in the total amount of P67,166,766.36 (P76,091,087.98 less P8,924,321.62) may be a proper subject of a refund claim pursuant to Section 229 of the NIRC of 1997, as amended. Based on the record of the case, petitioner derived its gross sales to government from its build, transfer and operate contract (BTO Contract) with the NSO for the design, development, construction, installation, testing and commissioning of NSO's Civil Registry System-Information Technology, which provides that petitioner will receive a percentage of the revenues generated by the NSO from the services rendered under its CRS-IT. For the second quarter of CY 2009 to the third quarter of CY 2010, petitioner generated gross sales in the aggregate amount of P1,213,112,410.82, broken down as follows: Period Private Sales Sales to Total Government 2009 2nd Quarter p 8 539 710.51 p 222 035 976.18 p 230 575 686.69 3rd Quarter 7 192 998.36 169 331 838.06 176 524 836.42 4th Quarter 6 851 970.50 163 130 774.10 169,982 744.60 2010 1st Quarter 7 410 900.09 179 659 999.79 187,070,899.88 2nd Quarter 8,516,341.05 236,830 465.55 245,346,806.60 3rd Quarter 7,591,842.80 196 019 593.83 203 611 436.63 Total P46 103 763.31 P1 167 008,647.51 P1,213, 112,410.82 / To substantiate its sales to government in the amount of P1,167,008,647.51, petitioner presented the official

Decision C.T.A. CASE NO. 8293 receipts it issued to the NSO. The said revenues were duly reported in petitioner's Amended VAT Returns and were subjected to the corresponding 12% VAT and to 5% final VAT, which it withheld pursuant to Section 114(C) of the NIRC of 1997, as amended. 68 Moreover, to be entitled to refund/TCC, petitioner must prove that it incurred and had enough input tax credits and VAT payments. An examination of the record shows that petitioner's VAT payments consisted of the following: Period Actual VAT 5%VAT Total VAT withheld by Payments 2009 payments upon NSO supported 2nd filing of Quarter by BIR Form April original VAT No. 230770 returns69 Mav p 4,133,377.31 p 3,477,715.67 p 7,611,092.98 June 3rd 4 079,198.14 3,358,851.16 7,438,049.30 Quarter 5,297,570.66 4,265,231.98 9,562,802.64 68 "SEC. 114. Return and Payment of Value-added Tax. - XXX XXX XXX (C) Withholding of Creditable Value-added Tax. -The Government or any of its political subdivisions, instrumentalities or agencies, including government-owned or controlled-corporations (GOCCs) shall, before making payment on account of each purchase of goods from sellers and services rendered by contractors which are subject to the value-added tax imposed in Sections 106 and 108 of this Code, deduct and withhold the value-added tax due at the rate of five percent (5%) of the gross payment thereof: Provided, That the payment for lease or use of properties or property rights to non- resident owners shall be subject to ten percent (10%) withholding tax at the time of payment. For purposes of this Section, the payor or person in control of the payment shall be considered as the withholding agent." 69 Exhibits "JJJ-2"1 "LLL-2"I "AA"I "NNN-2"f "PPP-2"I "BB"I "RRR-2"I "TTT-2"I "CC"I "VW-2", "XXX-2", "DD", "ZZZ-2", "BBBB-2", "EE", "DDDD-2", "FFFF-2", and "FF", docket, pp. 597, 607, 507, 617, 627, 508, 637, 647, 509, 657, 667, 510, 675, 681, 511, 687, 693, and 512, respectively. / 70 Exhibits "II"I "JJ"I "KK"I "LL"I "MM"I "NN"I ''00"I "PP"I "QQ"I "RR"I "SS"I "TT"I "UU", "VV", "WW", "XX", "YY", and "ZZ", docket, pp. 517, 519, 521, 523, 525, 527, 529, 531, 533, 535, 537, 539, 541, 543, 545, 547, 549, and 551, respectively.

Decision C.T.A. CASE NO. 8293 July 3,925,140.40 3,121,927.37 7,047,067.77 August 2,964,278.01 2,870,308.92 5,834,586.93 September 3,197,817.09 2,474,355.61 5,672,172.70 4th Quarter October 3 480 657.46 2 721 988.37 6 202 645.83 November 3,378,612.26 2,833A52.59 6,212,064.85 December 3A54A37.07 2 601 097.75 6,055,534.82 2010 1st Quarter 2,567,289.81 2 086 271.92 4,653,561. 73 January 4,267,623.74 3A06J87.97 7,674A11.71' February 4,606,575.14 3 489 940.09 8,096,515.23 ! March 4,544,027.78 3 895,019.19 . 2nd 4,047,711. 79 3,740,266.91 Quarter 5,568,193.82 4,206,237.17 8A39,046.97 7,787,978. 70 � April 4A30,051.66 3,704,193.04 9J74A30.99 May 4,105,885.45 3,174,665.97 June 3J83J55.91 2,922,120.68 8,134,244.70 3rd P71,832,203.50 P58,350,432.36 7,280,551.42 Quarter 6,705,876.59 July P130,182,635.86 August September Total However, of the P58,350,432.36 total VAT withheld by the NSO, the amount of P3,895,019.19 pertaining to the month of April 201071 shall be disallowed as tax credit since its supporting Certificate of Creditable Tax Withheld at Source (BIR Form No. 2307) lacks the signature of the authorized signatory; thus, shall bear no weight. Consequently, only the amount of P54,455,413.17 (P58,350,432.36 less P3,895,019.19) is considered as VAT withheld by NSO, which may be credited against its output liability. On the other hand, petitioner reported input VAT from the second quarter of CY 2009 to the third quarter of CY 2010 in the total amount of P22,588,300.99, summarized per quarter as follows: PERIOD AMOUNT 2009 2nd Quarter p 3,057,136.96 3rd Quarter 5,083,038.41 / 4th Quarter 4.000,190.73 71 Exhibit "UU".

Decision 2,024,019.25 C.T.A. CASE NO. 8293 3,440,159.98 Page 21 of 24 4,983,755.66 P22,588,300. 99 2010 1st Quarter 2nd Quarter 3rd Quarter Total To substantiate the foregoing figures, petitioner submitted various suppliers' invoices and official receipts72 and its Monthly Remittance Returns of Value-added Tax and Other Percentage Taxes Withheld (BIR Form No. 1600)73 � Upon scrutiny of the said documents, the Court finds that the input VAT amount of P12,083,947.19, as summarized below, should be disallowed for petitioner's failure to meet the substantiation requirements under Sections 110(A) and 113(A) and (B) of the NIRC of 1997, as amended by RA No. 9337, as implemented by Sections 4.110-2, 4.110-8, and 4.113-1 of RR No. 16-05: FINDINGS ANNEX AMOUNT 1. Input VAT on purchases of A goods/services supported by VAT B invoices/ORs wherein the input VAT c p 5,922.86 amount per invoice/OR is lower than D E the amount per claim (over-claimed F input VAT) 2. Input VAT on domestic purchases of goods/services supported by VAT invoices/ORs wherein the input VAT 6,154,663.67 157,629.07 amounts were not separately shown 383,663.24 393,472.00 3. Input VAT on domestic purchases of j 3,698,869. 72 goods/services supported by VAT invoices/ORs issued not in petitioner's name 4. Input VAT on domestic purchases of goods/services supported by VAT invoices/ORs dated outside the period of claim or were not dated 5. Input VAT on domestic purchases of goods/services supported by invoices/ORs with supplier's TIN but without the word "VAT" 6. Input VAT on domestic purchases of goods supported by documents other than VAT invoices 72 Exhibits "MMMMM" to "SSSSS". 73 Exhibits "BBB" to "DDD".

Decision C.T.A. CASE NO. 8293 7. Input VAT on domestic purchases of services supported by documents G 193,149.52 other than VAT DRs 8. Input VAT on domestic purchases of services supported by documents H 24,164.00 other than VAT DRs and issued not in petitioner's name 9. Input VAT on domestic purchases of goods/services supported by documents other than VAT I 924,914.94 invoices/DRs with printed notation "not a valid source of input tax" 10. Input VAT on domestic pyrchases of goods and services supported by J 15,982.98 photocopy of VAT invoices/DRs 11. Unaccounted/unsupported input K VAT claim 121,515.19 TOTAL P12,083,947.19 Consequently, only the remaining input VAT of P10,504,353.80 (P22,588,300.99 less P12,083,947.19) represents petitioner's valid input VAT for the second quarter of CY 2009 to the third quarter of CY 2010, which may be credited against petitioner's output VAT for the same period. In fine, petitioner was able to substantiate erroneous VAT payments of P51,187,799.96 only, as computed below: Output VAT per Returns P2,710,161.52 5,532,451.60 Sales to Private 2,822,290.08 p *CY 2009 (P3,714,837.46-P1,004,675.94) 66,539,830.60 140,041,037.70 CY 2010 73,501,207.10 P145,573,489.30 Sales to Government 10,504,353.80 *CY 2009 (P85,840,057.30-P19,300,226.70) P27,156,130.17 70,473,672.59 CY 2010 32,813,188.62 59,969,318.79 p 75,099,816.71 Total Output VAT Less: Input VAT 71 832,203.50 / 126,287,616.67 Valid Input VAT 54,455,413.17 Input Tax on Sale to Government closed to expense *CY 2009 (P36,080,451.55- P8,924,321.38) CY 2010 Net VAT Payable Less: VAT Payments Actual Payments VAT Withheld on Sales to Government

Decision I P(51,187,799.96) I C.T.A. CASE NO. 8293 IVAT Overpayment Moreover, based on its Quarterly VAT Returns from the fourth quarter of CY 2010 to the second quarter of CY 2012 74, petitioner did not carry over the input VAT of P76,091,087.98, which is the subject matter of the present claim. The said amount was neither presented as "Input tax carried over from previous period" nor claimed or utilized as deduction from output VAT in the subsequently filed returns for the fourth quarter of CY 2010 to the second quarter of CY 2012. WHEREFORE, the instant Petition for Review is hereby PARTIALLY GRANTED. Accordingly, respondent is hereby ORDERED TO REFUND or TO ISSUE A TAX CREDIT CERTIFICATE in favor of petitioner in the reduced amount of P51,187,799.96, representing petitioner's erroneous payments of VAT for the second to fourth quarters of CY 2009 and the succeeding three quarters of CY 2010. SO ORDERED. ESPEKA.NA' We Concur: <Pul. ~A L_� LOVEaAUTISTA MA. BELEN M. RINGPIS-LIBAN Associate Justice As~ociate Justice 74 Exhibits "TTTTT" to "YYYYY" and "BBBBBBB".

Decision C.T.A. CASE NO. 8293 ATTESTATION I attest that the conclusions in the above Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. LOVEL~ R. BAUTISTA Associate Justice Chairperson CERTIFICATION Pursuant to Section 13 of Article VIII of the Constitution, and the Division's Chairperson's Attestation, it is hereby certified that the conclusions in the above Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. ~~~ Presiding Justice

Annex A UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Purchases of goods/seiVices supported by VAT invoices/ORs wherein the input VAT amount per invoice/OR is lower than the amount per claim ( overclilim) Name of Supplier Exhibit OR amount Amount claimed Overclaim INNOVE COMMUNICATIONS INC. NNNNN-12 25 612.51 26 809.36 1196.85 IN NOVE COMMUNICATIONS INC. NNNNN-13 80.36 IN NOVE COMMUNICATIONS INC. NNNNN-19 1 719.64 1800.00 169.42 IN NOVE COMMUNICATIONS INC. NNNNN-20 INNOVE COMMUNICATIONS INC. NNNNN-21 3 625.50 3 794.92 1 643.31 BAYAN TELECOMMUNICATIONS INC. NNNNN-24 80.36 BAYAN TELECOMMUNICATIONS INC. NNNNN-25 35 166.89 36 810.20 BAYAN TELECOMMUNICATIONS INC. NNNNN-26 391.07 INNOVE COMMUNICATIONS INC. NNNNN-122 1 719.64 1 800.00 24.90 INNOVE COMMUNICATIONS INC. NNNNN-123 26.79 INNOVE COMMUNICATIONS INC. NNNNN-124 8 368.93 8,760.00 BAYAN TELECOMMUNICATIONS, INC. 00000-13 251.40 BAYAN TELECOMMUNICATIONS, INC. 00000-14 532.84 557.74 1 541.81 BAYAN TELECOMMUNICATIONS INC. 00000-15 BAYAN TELECOMMUNICATIONS, INC. 00000-19 573.21 600.00 80.36 BAYAN TELECOMMUNICATIONS, INC. 00000-20 5 380.00 5 631.40 391.08 BAYAN TELECOMMUNICATIONS, INC. 00000-21 32 994.68 34 536.49 26.79 ABOmz ONE INC. 00000-104 1 719.64 1 800.00 26.79 ABOmz ONE INC. PPPPP-11 391.07 ABOmz ONE INC. PPPPP-12 8 368.92 8 760.00 26.79 ABOmZ ONE INC. PPPPP-13 26.79 BAYAN TELECOMMUNICATIONS, INC. PPPPP-14 573.21 600.00 121.58 BAYAN TELECOMMUNICATIONS, INC. PPPPP-15 573.21 600.00 304.91 BAYAN TELECOMMUNICATIONS, INC. PPPPP-16 BAYAN TELECOMMUNICATIONS, INC. PPPPP-21 8 368.93 8 760.00 6.07 ABOmz ONE INC. PPPPP-24 373.14 ABOmZ ONE INC. PPPPP-25 573.21 600.00 391.07 ABOmZ ONE INC. PPPPP-109 ZENSHIN SYSTEMS CORPORATION PPPPP-116 573.21 600.00 26.79 BAYAN TELECOMMUNICATIONS PPPPP-138 26.79 BAYAN TELECOMMUNICATIONS PPPPP-139 7 911.18 8 032.76 26.79 BAYAN TELECOMMUNICATIONS PPPPP-140 327.24 ABOmz ONE INC 20 256.54 20 561.45 85.00 ABOmz ONE INC -23 399.42 405.49 75.33 ABOmz ONE INC -25 3 192.86 BAYAN TELECOMMUNICATIONS, INC. -27 2S 076.64 25 449.78 391.07 QQQQQ-28 26.79 BAYAN TELECOMMUNICATIONS INC. -29 8,368.93 8,760.00 26.79 BAYAN TELECOMMUNICATIONS, INC. QQQQQ-30 255.83 -36 573.21 600.00 149.07 BAYAN TELECOMMUNICATIONS INC. -37 354.18 BAYAN TELECOMMUNICATIONS INC. QQQQQ-45 573.21 600.00 342.86 BAYAN TELECOMMUNICATIONS, INC. QQQQQ-108 573.21 600.00 26.79 BAYAN TELECOMMUNICATIONS, INC. -109 26.79 -110 21 286.44 21 613.68 BAYAN TELECOMMUNICATIONS INC. 342.86 BAYAN TELECOMMUNICATIONS INC. RRRRR-103 6 570.67 6 655.67 26.79 BAYAN TELECOMMUNICATIONS, INC. 26.79 RRRRR-104 6 164.59 6 239.92 BAYAN TELECOMMUNICATIONS, INC. 348.63 RRRRR-105 1,328.57 4,521.43 26.79 BAYAN TELECOMMUNICATIONS, INC. RRRRR-106 26.79 INNOVE COMMUNICATIONS RRRRR-107 8 368.93 8 760.00 IN NOVE COMMUNICATIONS RRRRR-108 342.86 IN NOVE COMMUNICATIONS 573.21 600.00 26.79 Total 573.21 600.00 15 846.69 16 102.52 26.79 263.57 9 674.70 9 823.77 1,468.91 23 896.16 24 250.34 61.61 15 922.86 7,337.14 7,680.00 573.21 600.00 573.21 600.00 7 337.14 7 680.00 573.21 600.00 573.21 600.00 7,505.56 7,854.19 573.21 600.00 573.21 600.00 7,337.14 7,680.00 573.21 600.00 573.21 600.00 5 640.43 5 904.00 31 434.42 32 903.33 1,318.39 1,380.00 366,955.58 382,878.44

Annex B UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs wherein the input VAT were not separately shown Name of Supplier Exhibit Amount M2 KLEEN CARPET CLEANING NNNNN-14 535.71 M2 KLEEN CARPET CLEANING NNNNN-23 535.71 RICOH PHILIPPINES INC NNNNN-67 145.20 AIRFREIGHT 2100, INC. NNNNN-71 128 903.13 BAYAN TELECOMMUNICATIONS INC. NNNNN-72 9 360.00 BAYAN TELECOMMUNICATIONS INC. NNNNN-73 600.00 BAYAN TELECOMMUNICATIONS INC. NNNNN-74 600.00 FIRST 3K GROUP BUILDERS CORP. NNNNN-75 4 521.44 HOBBIES OF ASIA INC. NNNNN-76 9 360.00 KALT AIRE ENGINEERING SERVICES NNNNN-77 10 032.001 ROSECO MARKETING VENTURES NNNNN-78 41988.59 SKYFRESH INTERNATIONAL CORPORATION NNNNN-79 16 415.33 WELLCOME PRINTING SERVICES NNNNN-81 8 785.71 WELLCOME PRINTING SERVICES NNNNN-82 30 085.71 RICOH PHILIPPINES INC NNNNN-83 409.68 RICOH PHILIPPINES INC NNNNN-84 RICOH PHILIPPINES INC NNNNN-85 99.74 SYSTEMS GENERATORS PHILIPPINES, INC. NNNNN-86 186 838.25 21 735.66 ULTIMATE SECURITY AGENCY AND ALLIED SERVICES, INC. NNNNN-87 48,532.65 BAYAN TELECOMMUNICATIONS, INC. NNNNN-89 BAYAN TELECOMMUNICATIONS, INC. NNNNN-90 8 760.00 BAYAN TELECOMMUNICATIONS, INC. NNNNN-91 600.00 CLEAN CITY COMMERCIAL INC NNNNN-92 600.00 RICOH PHILIPPINES INC NNNNN-95 RICOH PHILIPPINES INC NNNNN-96 2 786.10 SUNFREIGHT FORWARDERS AND CUSTOMS BROKERAGE,_ INC. NNNNN-97 130.08 SYSTEMS GENERATORS PHILIPPINES, INC. NNNNN-98 505.60 ULTIMATE SECURITY AGENCY AND ALLIED SERVICES, INC. NNNNN-99 W ELLCOME PRINTING SERVICES NNNNN-100 2,727.27 W ELLCOME PRINTING SERVICES NNNNN-101 AIRFREIGHT 2100, INC. NNNNN-102 21J35.66 RICOH PHILIPPINES INC NNNNN-103 49p5.87 RICOH PHILIPPINES INC NNNNN-104 SUPERCLEAN SERVICES CORPORATION NNNNN-105 251601.79 NNNNN-106 14,142.86 ULTIMATE SECURITY AGENCY AND ALLIED SERVICES, INC NNNNN-107 55,985.79 ULTIMATE SECURITY AGENCY AND ALLIED SERVICES, INC NNNNN-108 WELLCOME PRINTING SERVICES NNNNN-116 409.68 ULTIMATE SECURITY AGENCY AND ALLIED SERVICES INC. NNNNN-117 356,858.77 HOBBIES OF ASIA INC. NNNNN-120 CONSNET BUILDERS INC NNNNN-121 16 481.50 HOBBIES OF ASIA INC. NNNNN-125 47 938.01 M2 KLEEN CARPET CLEANING NNNNN-126 48,532.57 M2 KLEEN CARPET CLEANING NNNNN-127 SUPERCLEAN SERVICES CORPORATION NNNNN-128 2 410.71 SYSTEMS GENERATORS PHILIPPINES INC. NNNNN-133 49,371.43 FIRST 3K GROUP BUILDERS CORP. NNNNN-143 FIRST 3K GROUP BUILDERS CORP. 00000-10 9 360.00 M2 KLEEN CARPET CLEANING 00000-12 3 702.00 ABOmZ ONE, INC. 00000-16 9 360.00 M2 KLEEN CARPET CLEANING 00000-41 RICOH PHILIPPINES INC 00000-54 375.00 AIRFREIGHT 2100, INC. 00000-55 535.71 BAYAN TELECOMMUNICATIONS, INC. 00000-56 16 472.66 BAYAN TELECOMMUNICATIONS, INC. 00000-57 21,733.32 BAYAN TELECOMMUNICATIONS, INC. 28 800.00 9 674.40 375.00 27 689.88 1,046.25 570.21 61 760.57 8 760.00 600.00 600.00

Annex B UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs wherein the input VAT were not separately shown -- Name of Supplier Exhibit Amount FIRST 3K GROUP BUILDERS CORP. 00000-58 4 521.44 00000-59 4 521.44 FIRST 3K GROUP BUILDERS CORP. 00000-60 25 848.69 00000-65 9 360.00 FIRST 3K GROUP BUILDERS CORP. 00000-68 00000-69 409.68 HOBBIES OF ASIA INC. 00000-70 11 976.00 00000-71 51 668.79 RICOH PHILIPPINES INC 00000-72 42 261.44 00000-75 9 360.00 ROSECO MARKETING VENTURES 00000-76 186 554.63 00000-77 391 245.31 AIRFREIGHT 2100, INC. 00000-78 13,632.00 00000-79 FIRST 3K GROUP BUILDERS CORP. 00000-80 4,665.39 00000-81 16 670.92 HOBBIES OF ASIA, INC. 00000-82 16 472.66 00000-83 49,275.79 RICOH PHILIPPINES INC 00000-84 00000-85 2 410.71 RICOH PHILIPPINES INC 00000-86 20,169.64 00000-89 ROSECO MARKETING VENTURES 00000-90 5,038.39 00000-91 50,528.14 ROSECO MARKETING VENTURES 00000-92 00000-97 250.71 SUPERCLEAN SERVICES CORPORATION 00000-98 539.35 00000-99 991.66 SUPERCLEAN SERVICES CORPORATION 00000-100 16 273.89 00000-101 13 017.86 ULTIMATE SECURITY AGENCY AND ALLIED SERVICES INC. 00000-102 2.410.71 00000-103 9 642.86 WELLCOME PRINTING SERVICES 00000-107 3 256.03 00000-108 375.00 WELLCOME PRINTING SERVICES 00000-109 21,521.43 00000-110 21,714.13 WELLCOME PRINTING SERVICES 00000-111 18 594.30 AIRFREIGHT 2100 INC . 00000-112 9 360.00 00000-113 CLEAN CITY COMMERCIAL INC 00000-139 321.43 72 860.41 RICOH PHILIPPINES INC PPPPP-18 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES PPPPP-68 1464.12 PPPPP-69 21,414.95 SUPERCLEAN SERVICES CORPORATION PPPPP-70 PPPPP-71 84,385.70 WELLCOME PRINTING SERVICES PPPPP-72 33 750.64 PPPPP-73 72 860.41 WELLCOME PRINTING SERVICES PPPPP-74 PPPPP-75 535.71 WELLCOME PRINTING SERVICES PPPPP-76 140.50 PPPPP-77 260.08 ABOmz ONE, INC. PPPPP-78 4 521.44 PPPPP-79 4 521.44 M2 KLEEN CARPET CLEANING PPPPP-80 9 360.00 PPPPP-84 9 857.14 SYSTEMS GENERATORS PHILIPPINES INC. 409.68 129.72 SYSTEMS GENERATORS PHILIPPINES, INC. 8 160.00 2,025.72 ABOmz ONE, INC. 16 538.83 21,300.20 HOBBIES OF ASIA. INC. 2 290.18 2,531.25 M2 KLEEN CARPET CLEANING MICROIMAGING SALES AND SERVICES, INC. MY SECURE SIGN INC SYSTEMS GENERATORS PHILIPPINES, INC. ULTIMATE SECURITY AGENCY AND ALLIED SERVICES W ELLCOME PRINTING SERVICES MICROIMAGING SALES AND SERVICES M2 KLEEN CARPET CLEANING AIRFREIGHT 2100 INC. AIRFREIGHT 2100, INC. FIRST 3K GROUP BUILDERS CORP. FIRST 3K GROUP BUILDERS CORP. HOBBIES OF ASIA, INC. MH POLY ELECTROMECHS INC RICOH PHILIPPINES INC RICOH PHILIPPINES INC ROSECO MARKETING VENTURES SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES SUPERCLEAN SERVICES CORP SYSTEMS GENERATORS PHILIPPINES, INC. W ELLCOME PRINTING SERVICES W ELLCOME PRINTING SERVICE

Annex B UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs wherein the input VAT w-- ere not sepa-r-at-ely s-h-ow---n- Name of Supplier Exhibit Amount FIRST 3K GROUP BUILDERS CORP. PPPPP-85 6 711.75 FIRST 3K GROUP BUILDERS CORP. 4,521.44 HOBBIES OF ASIA. INC. PPPPP-87 9,360.00 RICOH PHILIPPINES INC SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES PPPPP-89 528.88 W ELLCOME PRINTING SERVICE 2,169.90 W ELLCOME PRINTING SERVICE PPPPP-93 19 189.29 AIRFREIGHT 2100 INC. PPPPP-95 4 628.57 LANTRO PHILS INC 43 098.43 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES PPPPP-96 56 250.00 WELLCOME PRINTING SERVICES 1,973.98 WELLCOME PRINTING SERVICES PPPPP-97 2 410.71 WELLCOME PRINTING SERVICES 3 803.57 WELLCOME PRINTING SERVICES PPPPP-98 12 042.86 WELLCOME PRINTING SERVICES 2 117.14 M2 KLEEN CARPET CLEANING PPPPP-100 14 228.57 RICOH PHILIPPINES INC SYSTEMS GENERATORS PHILIPPINES, INC. PPPPP-101 535.71 HOBBIES OF ASIA, INC. 372 888.37 SYSTEMS GENERATORS PHILIPPINES, INC. PPPPP-102 FIRST 3K GROUP BUILDERS CORP. 21 526.75 SUPERCLEAN SERVICES CORP PPPPP-103 9 360.00 MICROIMAGING SALES AND SERVICES INC. 21 735.66 AIRFREIGHT 2100 INC PPPPP-104 4 521.44 AIRFREIGHT 2100 INC 16 472.41 FIRST 3K GROUP BUILDERS CORP. PPPPP-105 72,860.41 FIRST 3K GROUP BUILDERS CORP. 84 485.68 HOBBIES OF ASIA INC PPPPP-108 37 783.82 M2 KLEEN CARPET CLEANING 4,521.44 MH POLY ELECTROMECHS INC PPPPP-110 4 521.44 RICOH PHILIPPINES INC 9 360.00 RICOH PHILIPPINES INC PPPPP-111 1 046.25 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES 27 916.07 SUPERCLEAN SERVICES CORPORATION PPPPP-112 SYSTEMS GENERATORS PHILIPPINES INC. 409.68 WELLCOME PRINTING SERVICES PPPPP-113 369.61 WELLCOME PRINTING SERVICES 1 996.14 WELLCOME PRINTING SERVICES PPPPP-114 16 140.31 MICROIMAGING SALES AND SERVICES, INC. 17 487.12 AIRFREIGHT 2100 INC PPPPP-115 2 603.57 HOBBIES OF ASIA INC 1 901.79 M2 KLEEN CARPET CLEANING PPPPP-144 13 014.64 RICOH PHILIPPINES INC 72 860.41 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES PPPPP-146 30 015.32 WELLCOME PRINTING SERVICES 9 828.00 WELLCOME PRINTING SERVICES -68 1446.42 WELLCOME PRINTING SERVICES 373 032.50 WELLCOME PRINTING SERVICES -69 2,05!:>.10 WELLCOME PRINTING SERVICES 2 237.14 RICOH PHILIPPINES INC -70 20 812.50 RICOH PHILIPPINES INC 2 025.00 SYSTEMS GENERATORS PHILIPPINES, INC. -71 669.64 WELLCOME PRINTING SERVICES 9 000.00 WELLCOME PRINTING SERVICES -72 1 070.44 WELLCOME PRINTING SERVICES 471.19 -73 42,143.79 1 496.79 -74 35 729.46 10 285.71 -75 -76 -78 -79 -80 -81 -82 -83 -84 -85 -86 -87 1., -88 -89 -90 -91 -92 -93 -94 -96 -97 -98 -99 -100 -101

Annex B UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs wherein the input VAT were not separately shown Name of Supplier Exhibit Amount BAYAN TELECOMMUNICATIONS, INC. -102 1 230.00 FIRST 3K GROUP BUILDERS CORP. -103 8 750.38 AIRFREIGHT 2100 INC -107 HOBBIES OF ASIA INC -111 152.54 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES -112 9 828.00 M2 KLEEN CARPET CLEANING -139 2 141.27 M2 KLEEN CARPET CLEANING -140 SUPERCLEAN SERVICES CORPORATION -141 535.71 HOBBIES OF ASIA INC RRRRR-71 375.00 PIONEER INSURANCE AND SURETY CORPORATION RRRRR-72 32 481.87 RICOH PHILIPPINES INC RRRRR-73 9 828.00 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES RRRRR-74 1,638.97 SUPERCLEAN SERVICES CORPORATION RRRRR-75 WELLCOME PRINTING SERVICES RRRRR-76 578.72 WELLCOME PRINTING SERVICES RRRRR-77 2,139.36 WELLCOME PRINTING SERVICES RRRRR-78 16 252.67 FIRST 3K GROUP BUILDERS CORP. RRRRR-79 FIRST 3K GROUP BUILDERS CORP. RRRRR-80 750.00 FIRST 3K GROUP BUILDERS CORP. RRRRR-81 30 125.89 HOBBIES OF ASIA INC RRRRR-82 MICROIMAGING SALES AND SERVICES INC. RRRRR-83 1150.18 RICOH PHILIPPINES INC RRRRR-84 31 883.07 RICOH PHILIPPINES INC RRRRR-85 15 504.87 SECURITY AND SAFETY CORPORARTION OF THE PHILIPPINES RRRRR-87 SYSTEMS GENERATORS PHILIPPINES, INC. RRRRR-88 3 696.00 WELLCOME PRINTING SERVICES RRRRR-89 9 828.00 WELLCOME PRINTING SERVICES RRRRR-90 76,624.04 WELLCOME PRINTING SERVICES RRRRR-91 339 825.15 AIRFREIGHT 2100 INC RRRRR-92 HOBBIES OF ASIA INC RRRRR-94 467.16 RICOH PHILIPPINES INC RRRRR-95 2 139.36 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES RRRRR-96 21 735.66 WELLCOME PRINTING SERVICES RRRRR-97 17 100.00 WELLCOME PRINTING SERVICES RRRRR-98 13 954.29 WELLCOME PRINTING SERVICES RRRRR-99 18 697.50 FIRST 3K GROUP BUILDERS CORP RRRRR-100 103,724.47 SYSTEMS GENERATORS PHILIPPINES, INC. RRRRR-102 9 828.00 PHILIPPINE LONG DISTANCE RRRRR-133 AIRFREIGHT 2100 INC SSSSS-68 462.83 M2 KLEEN CARPET CLEANING SSSSS-69 2 139.36 FIRST 3K GROUP BUILDERS CORP. SSSSS-70 6 508.93 FIRST 3K GROUP BUILDERS CORP. SSSSS-71 FIRST 3K GROUP BUILDERS CORP. SSSSS-72 702.32 M2 KLEEN CARPET CLEANING SSSSS-73 30 766.61 PIONEER INSURANCE AND SURETY CORPORATION SSSSS-74 RICOH PHILIPPINES INC SSSSS-75 4 521.44 SECURITY AND SAFt: 1Y CORPORAKTION OF THE PHILIPPINES SSSSS-76 21 631.69 SUPERCLEAN SERVICES CORPORATION SSSSS-77 U BIX CORPORATION SSSSS-78 4 077.75 WELLCOME PRINTING SERVICES SSSSS-79 162 619.40 WELLCOME PRINTING SERVICES SSSSS-80 WELLCOME PRINTING SERVICES SSSSS-81 1 446.43 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES SSSSS-82 13 197.85 AIRFREIGHT 2100 INC SSSSS-83 8 904.87 HOBBIES OF ASIA INC SSSSS-84 8 904.87 1 446.43 275.75 467.73 2,142.60 32 635.57 389 960.09 25 500.00 4 076.79 5 337.32 2,320.83 50 867.79 9,828.00

Annex B UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs wherein the input VAT were not separately shown -- --- -- -- -- -- -- Name of Supplier Exhibit Amount HOBBIES OF ASIA INC SSSSS-8S 9 828.00 HOBBIES OF ASIA INC SSSSS-86 9 828.00 ISLA LIPANA AND CO SSSSS-87 6 102.00 M2 KLEEN CARPET CLEANING SSSSS-88 1 446.43 RICOH PHILIPPINES INC SSSSS-89 SUPERCLEAN SERVICES CORPORATION SSSSS-90 473.51 SUPERCLEAN SERVICES CORPORATION SSSSS-91 16 406.24 WELLCOME PRINTING SERVICES SSSSS-92 16 406.49 WELLCOME PRINTING SERVICES SSSSS-93 WELLCOME PRINTING SERVICES SSSSS-94 7 602.86 AIRFREIGHT 2100 INC SSSSS-95 19 453.93 CULINARY TREASURE FOOD SERVICES, INC. SSSSS-96 WELLCOME PRINTING SERVICES SSSSS-102 954.64 WELLCOME PRINTING SERVICES SSSSS-103 49 240.29 SYSTEMS GENERATORS PHILIPPINES INC. SSSSS-124 SYSTEMS GENERATORS PHILIPPINES, INC. SSSSS-135 1 202.46 Total HLQ10.36 1~923.21 21,735.66 21,735.66 6,154,663.67

Annex C UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs issued not in petitioner's name Name of Supplier Exhibit Amount MANILA ELECfRIC COMPANY NNNNN-15 865.28 MANILA ELECfRIC COMPANY 6 256.49 MANILA ELECfRIC COMPANY NNNNN-22 4 770.15 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-28 1,791.24 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 4 302.29 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-129 1,501.20 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 4 302.29 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-130 1,501.20 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 1329.84 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-131 4,338.96 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-132 1,791.24 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-137 1 791.24 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 4 302.29 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-138 1,501.20 26 011.93 ISLA LIPANA AND CO NNNNN-139 4 322.45 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 4,338.96 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-140 4 947.19 5,135.13 MANILA ELECfRIC COMPANY NNNNN-141 5 018.31 MANILA ELECfRIC COMPANY 1,501.20 MANILA ELECfRIC COMPANY NNNNN-142 1329.84 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 4,338.96 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-144 4 426.97 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-145 1 791.24 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY 4,664.86 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-146 4 821.41 MANILA ELECfRIC COMPANY 4 997.21 MANILA ELECfRIC COMPANY NNNNN-147 4,479.42 MANILA ELECfRIC COMPANY 1 700.63 MANILA ELECfRIC COMPANY NNNNN-152 5,234.S6 MANILA ELECTRIC COMPANY 6 069.06 MANILA ELECfRIC COMPANY NNNNN-153 9,579.00 MANILA ELECfRIC COMPANY 7 007.21 ISLA LIPANA AND CO. NNNNN-155 1,182.86 MANILA ELECfRIC COMPANY AMBASSADOR APPLIANCES INC 00000-11 157,~29.07 Total 00000-18 00000-23 00000-116 00000-117 00000-118 00000-120 00000-121 00000-123 PPPPP-19 PPPPP-23 PPPPP-27 -24 -26 -42 Ul -43 -113 RRRRR-65 SSSSS-60 '

Annex D UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by VAT invoices/ORs dated outside the period of claim or are not dated Name of Supplier Exhibit Amount WELLCOME PRINTING SERVICES NNNNN-80 3 857.14 AIRFREIGHT 2100 INC. NNNNN-88 66 047.11 CmPAPERINC NNNNN-109 33 310.71 E-PLUS STATIONERY INC NNNNN-110 INNOVEND CORPORATION NNNNN-111 2 614.29 INNOVEND CORPORATION NNNNN-112 103.04 SKYFRESH INTERNATIONAL CORPORATION NNNNN-113 SKYFRESH INTERNATIONAL CORPORATION NNNNN-114 1466.80 E-PLUS STATIONERY INC NNNNN-115 62.40 LANTRO PHILS INC 67.20 MICROIMAGING SALES AND SERVICES INC. -95 MH POLY ELECTROMECHS INC SSSSS-53 2 614.29 MY SECURE SIGN INC SSSSS-98 15 000.00 RICOH PHILIPPINES INC SSSSS-99 76 624.04 SECURITY AND SAFETY CORPORATION OF THE PHILIPPINES SSSSS-100 14 400.00 ABOmZ ONE INC SSSSS-101 BAYAN TELECOMMUNICATIONS INC. SSSSS-107 1 404.36 BAYAN TELECOMMUNICATIONS INC. SSSSS-108 457.82 BAYAN TELECOMMUNICATIONS INC. SSSSS-109 BAYAN TELECOMMUNICATIONS INC. SSSSS-110 2 313.80 BAYAN TELECOMMUNICATIONS INC. SSSSS-111 84 588.27 FIRST 3K GROUP BUILDERS CORP. SSSSS-112 SUPERCLEAN SERVICES CORPORATION SSSSS-113 7 080.00 SYSTEMS GENERATORS PHILIPPINES INC. SSSSS-115 600.00 SYSTEMS GENERATORS PHILIPPINES, INC. SSSSS-153 600.00 SSSSS-154 840.00 Total 829.29 8 904.87 16,406.49 21 735.66 21,735.66 383,663.24

Annex E UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by invoices/ORs with supplier's TIN but without the word "VAT" Name of Supplier Exhibit Amount GLOBE TELECOM INC NNNNN-93 204.00 GLOBE TELECOM INC 204.00 INNOVE COMMUNICATIONS, INC. NNNNN-94 5 522.80 GLOBE TELECOM INC 204.00 GLOBE TELECOM INC 00000-9 204.00 GLOBE TELECOM INC 204.00 GLOBE TELECOM INC 00000-61 204.00 INNOVE COMMUNICATIONS INC. 34,815.94 INNOVE COMMUNICATIONS INC. 00000-62 1800.00 INNOVE COMMUNICATIONS, INC. 5,724.00 INNOVE COMMUNICATIONS INC. 00000-63 36 015.48 GLOBE TELECOM INC 204.00 GLOBE TELECOM INC 00000-64 204.00 INNOVE COMMUNICATIONS INC. 5,693.65 INNOVE COMMUNICATIONS INC. 00000-66 34 159.20 IN NOVE COMMUNICATIONS INC. 1 800.00 GLOBE TELECOM INC 00000-67 204.00 GLOBE TELECOM INC 204.00 INNOVE COMMUNICATIONS INC. 00000-73 5,691.13 INNOVE COMMUNICATIONS INC. 35 314.93 INNOVE COMMUNICATIONS INC. 00000-74 1,800.00 GLOBE TELECOM INC 204.00 GLOBE TELECOM INC 00000-87 204.00 INNOVE COMMUNICATIONS INC. 5 693.73 INNOVE COMMUNICATIONS INC. 00000-88 35 244.11 INNOVE COMMUNICATIONS INC. 1800.00 GLOBE TELECOM INC 00000-93 612.00 INNOVE COMMUNICATIONS 17 123.92 INNOVE COMMUNICATIONS 00000-94 107 120.24 INNOVE COMMUNICATIONS 5 400.00 GLOBE TELECOM INC 00000-95 408.00 INNOVE COMMUNICATIONS 5,651.14 INNOVE COMMUNICATIONS 00000-105 36 220.98 INNOVE COMMUNICATIONS 1,800.00 IN NOVE COMMUNICATIONS 00000-106 5 612.75 393,472.00 Total PPPPP-81 PPPPP-82 PPPPP-83 PPPPP-86 PPPPP-88 PPPPP-90 PPPPP-91 PPPPP-92 -31 -32 -33 -34 VI -38 -39 -40 -44 RRRRR-53

Annex F UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods supported by documents other than VAT invoices Name of Supplier Exhibit Amount MERCURY INTERNATIONAL SECURITY PRINTING NNNNN-31 104,464.29 CORPORATION NNNNN-32 111,680.36 MERCURY INTERNATIONAL SECURITY PRINTING NNNNN-49 112,500.00 CORPORATION NNNNN-50 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING NNNNN-51 112,500.00 CORPORATION NNNNN-65 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING NNNNN-66 112,500.00 CORPORATION 00000-31 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING 00000-38 112,500.00 CORPORATION 00000-52 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING 00000-114 112,500.00 SERVICES INC 00000-136 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING PPPPP-36 112,500.00 SERVICES INC PPPPP-37 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING PPPPP-52 112,500.00 CORPORATION PPPPP-53 112,500.00 MERCURY INTERNATIONAL SECURITY PRINTING PPPPP-63 112,500.00 CORPORATION PPPPP-64 MERCURY INTERNATIONAL SECURITY PRINTING 7,425.00 SERVICES INC -46 202,500.00 MERCURY INTERNATIONAL SECURITY PRINTING -59 CORPORATION -138 22,500.00 MERCURY INTERNATIONAL SECURITY PRINTING RRRRR-41 384.00 CORPORATION RRRRR-46 MERCURY INTERNATIONAL SECURITY PRINTING RRRRR-47 2,619.64 CORPORATION RRRRR-57 742,500.00 MERCURY INTERNATIONAL SECURITY PRINTING RRRRR-66 225,000.00 CORPORATION SSSSS-97 249,750.00 MERCURY INTERNATIONAL SECURITY PRINTING 341,100.00 CORPORATION MERCURY INTERNATIONAL SECURITY PRINTING 1,446.43 CORPORATION 3,698,869.72 MERCURY INTERNATIONAL SECURITY PRINTING CORPORATION MISNET EDUCATION INC MERCURY INTERNATIONAL SECURITY PRINTING CORPORATION MERCURY INTERNATIONAL SECURITY PRINTING SERVICES SKYFRESH INTERNATIONAL CORPORATION AMBASSADOR APPLIANCES INC MERCURY INTERNATIONAL SECURITY PRINTING CORPORATION MERCURY INTERNATIONAL SECURITY PRINTING CORPORATION MERCURY INTERNATIONAL SECURITY PRINTING CORPORATION MERCURY INTERNATIONAL SECURITY PRINTING CORPORATION M2 KLEEN CARPET CLEANING Total

Annex G UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of services supported by documents other than VAT ORs Name of Supplier Exhibit Amount II PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-149 4.414.611 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-150 E M ZALAMEA ACTUARIAL SERVICES NNNNN-148 2 433.811 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY NNNNN-154 PHILIPPINE LONG 00000-141 1404.001 INNOVE COMMUNICATIONS INC. 00000-142 PHILIPPINE LONG 2 005.32i DISTANCE TELEPHONE 00000-145 SUPERCLEAN SERVICES CORPORATION PPPPP-106 2 005.32i ISUZU AUTOMOTIVE DEALERSH PPPPP-145 ROSECO MARKmNG VENTURES 1800.00 ROSECO MARKmNG VENTURES -77 GLOBE TELECOM INC RRRRR-86 2,005.32 INNOVE COMMUNICATIONS RRRRR-109 16 388.34 INNOVE COMMUNICATIONS RRRRR-110 INNOVE COMMUNICATIONS RRRRR-111 313.15 INNOVE COMMUNICATIONS SSSSS-117 600.00 INNOVE COMMUNICATIONS SSSSS-118 9,600.00 INNOVE COMMUNICATIONS SSSSS-119 204.00 GLOBE TELECOM INC SSSSS-120 13,176.77 GLOBE TELECOM INC SSSSS-121 1 380.00 IN NOVE COMMUNICATIONS SSSSS-122 5.904.00 SSSSS-123 33 320.13 Total 1 380.00 52 361.27 204.00 204.00 42 045.48 193,149.52

Annex H UNISYS PUBUC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of services supported by documents other than VAT ORs and issued not in petitioner's name Name of Supplier Exhibit Amount PHILIPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-128 4 338.96 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4.471.87 PHIUPPINE LONG DISTANCE PPPPP-135 PHIUPPINE LONG DISTANCE 843.12 PHIUPPINE LONG DISTANCE PPPPP-142 480.00 PHIUPPINE LONG DISTANCE 2 781.70 PHIUPPINE LONG DISTANCE PPPPP-143 1 008.00 PHILIPPINE LONG DISTANCE 5 658.93 ( -146 4 581.42 Total 24,164.00 -147 RRRRR-123 55555-137

Annex! UNISYS PUBUC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by documents other than VAT invoices/ORs with printed notation "not a valid source of input tax" Name of Supplier Exhibit Amount PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-115 4 302.29 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 338.96 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-119 1 329.84 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 501.20 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-122 4 302.29 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 338.96 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-124 4 452.92 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 2 005.321 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-125 1 096.44, PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 791.24 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-126 5 169.50 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-127 1 791.24 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 302.29 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-128 1 501.20 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 329.84 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-129 4 302.29 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 302.29 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-130 1 791.24 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 2 016.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-131 3 543.93 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 2 715.42 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-132 1 501.20 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 669.94 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-133 2 005.32 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-134 1 791.24 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 5 203.34 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-135 2 005.32 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 096.44 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 00000-143 1,329.84 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 2 270.81 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-94 1 008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1,008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-99 1 501.20 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 3 825.09 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-118 17 355.84 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 8,604.58 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-119 4 338.96 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 13 990.82 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-120 6,015.96 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 872.69 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-121 5 373.72 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 032.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-122 2,016.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 2 016.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-123 1 008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 3 024.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-124 2,016.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-125 960.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 8 604.58 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-126 4 338.96 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 4 802.09 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-129 1 791.24 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 6 048.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY PPPPP-130 1 008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 1 008.00 PPPPP-131 1,008.00 PPPPP-132 PPPPP-133 PPPPP-134 PPPPP-136 PPPPP-137 PPPPP-141 -114 l..ll..ll..ll..ll..l-115 -116 -117 -118 ~ -119 -120 ooooo-121 l..ll..ll..ll..ll..,!-122 -123 -124 QQQQQ-125 QQQQQ-126 -127 nooo0-128 -129 l..ll..ll..ll..ll..,!-130 -131 oooor -132 I.JI..ll..ll..ll..l-133 -134 00000-135

Annex I UNISYS PUBUC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by documents other than VAT invoices/ORs with printed notation "not a valid source of input tax" Name of Supplier Exhibit Amount PHILIPPINE LONG DISTANCE TELEPHONE COMPANY -136 480.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-113 4 302.29 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-114 4 338.96 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-115 4,960.94 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-116 1 008.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-117 1008.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-118 1,008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-119 1 008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-120 1 008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-121 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-122 480.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-124 4 338.96 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-125 2 016.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-126 1 008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-127 1,008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-128 1 008.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-129 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-130 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-131 480.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-132 2 105.11 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-134 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-135 4 338.96 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-136 1,008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-137 2 016.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-138 1 008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-139 1.008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-140 1 008.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-141 1 008.00 FIRST 3K GROUP BUILDERS CORP. RRRRR-143 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-144 480.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-146 1 008.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY RRRRR-148 4 521.44 MERCURY INTERNATIONAL SECURITY PRINTING 1 791.24 CORPORATION SSSSS-39 1,008.00 MERCURY INTERNATIONAL SECURITY PRINTING 2 016.00 CORPORATION SSSSS-40 MERCURY INTERNATIONAL SECURITY PRINTING 129,150.00 CORPORATION SSSSS-52 MERCURY INTERNATIONAL SECURITY PRINTING 92,250.00 CORPORATION SSSSS-61 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-125 226 800.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-126 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-127 183,150.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-128 4,338.96 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-129 3 958.95 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-130 1 008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-131 2,016.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-132 1 008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-133 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-134 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-136 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-138 480.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-139 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-140 4,338.96 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-141 1008.00 PHiliPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-142 1 817.16 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-143 1 008.00 PHILIPPINE LONG DISTANCE TELEPHONE COMPANY SSSSS-144 1 008.00 1 008.00 1 008.00 4,338.96

Annex I UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods/services supported by documents other than VAT invoices/ORs with printed notation "not a valid source of input tax" Name of Supplier Exhibit Amount PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-145 4 999.29 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-146 1 008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-147 1 008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-148 1008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-149 1,008.00 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-150 PHIUPPINE LONG DISTANCE TELEPHONE COMPANY 55555-151 480.00 Total 1.008.00 924,914.94

Annex J UNISYS PUBLIC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Input VAT on Domestic purchases of goods and services supported by photocopy of VAT invoices/ORs Name of Supplier Exhibit Amount E M ZALAMEA ACTUARIAL SERVICES -144 1404.00 ISLA LIPANA AND CO 14 098.98 PHILIPPINE LONG DISTANCE -145 SSSSS-157 480.00 Total 15,982.98

Annex K UNISYS PUBUC SECTOR SERVICES CORPORATION CTA CASE NO. 8293 Unaccounted/unsupported input VAT claim Exhibit/Reference Amount of Input VAT PPPPP-66 1 328.57 Particulars 7,686.62 Exhibit not found in the records of the case Supporting documents not available for 112,500.00 verification 121515.19 No supporting documents for purchase from Mercury International Sec with invoice no. 11043 Total