COMMISSIONER OF INTERNAL REVENUE v. GOVERNMENT OF SINGAPORE INVESTMENT CORPORATION PTE LTD.,

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY ENBANC COMMISSIONER OF INTERNAL CTA EB NO. 958 REVENUE, (CTA CASE NO. 8030) Petitioner, Present: -versus- Del Rosario, P.]., Castaneda, GOVERNMENT OF SINGAPORE Bautista, INVESTMENT CORPORATION Uy, PTE., LTD., Casanova, Fabon-Victorino, Respondent. Mindaro-Grulla, Cotangco-Manalastas, and Ringpis-Liban Jl Promulgated: X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -' - - - - - - X RESOLUTION RINGPIS-LIBAN,J. This resolves Petitioner's "Motion for Reconsideration (Re: Decision dated 31 March 2014)" flled on April28, 2014 by registered mail1 seeking to s~t aside the Decision2 promulgated March 31, 2014 and a new one be entered dismissing the claims of Respondent in its entirety. In response thereto, Respondent flied its "Comment (To Petitioner's Motion for Reconsiderationf" on August 4, 2014. ~ I Full compliance pursuant to Section 4, Rule 5 of the Revised Rules of Court of Tax Appeals was made by petitioner on May 12, 2014. 2 Rollo, pp. 109 to 125 3 Rollo, pp . 160 to 176

RESOLUTION CTA EB No. 958 (CTA CASE No. 8030) The dispositive portion of the decision dated March 31, 2014 reads as follows: "WHEREFORE, premises considered, finding no error in the appealed Decision, the Petition for Review is hereby DENIED. The appealed Decision dated September 5, 2012 is hereby AFFIRMED." In her motion, petitioner contended that (1) Respondent miserably failed to prove that it is a financial institution wholly-owned and controlled by the Government of Singapore4, and (2) Respondent failed to prove that it is entitled to claim for refund in the amount of P12,968,416.71 for alleged erroneously withheld final tax5. After a careful consideration of the grounds raised in the Motion for Reconsideration, the Court finds that the issues and arguments raised therein had already been amply discussed, passed upon and considered by this Court in the Decision sought to be reconsidered. The arguments stated therein constitute neither compelling nor cogent reason to modify, much less reverse our Decision dated March 31, 2014. WHEREFORE, premises considered, petitioner Commissioner of Internal Revenue's "Motion for Reconsideration (Re: Decision dated 31 March 2014)" is hereby DENIED for lack of merit. SO ORDERED. (JX.~ h '-' MA. BELEN M. RINGPIS-LIBAN Associate Justice We Concur: Presiding Justice (]_ c .a;r~ \J.. - LOVELE R. BAUTISTA mANfio c. cAsTA:NEnR,'JR. Associate Justice 4 Rollo, p. 143 5 Rollo, p. 146

RESOLUTION CAESA~ASANOVA CTA EB N o. 958 (CTA CASE No. 8030) Associate Justice ~ N M~~~ C~ . CIELITO N: MlNDARO-GRULLA ERLI~2ERA-UY Associate Justice Asso e Justice d_~ ~ ;;/J~---//- AM~~TANGCO-MANALASTAS Associate Justice