TOLEDO POWER COMPANY v. COMMISSIONER OF INTERNAL REVENUE

I' REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SECOND DIVISION TOLEDO POWER COMPANY, CTA CASE NO. 11271 Petitioner, Members: -versus- RINGPIS-LIBAN, Chairperson, MODESTO-SAN PEDRO, and FERRER-FLORES, JJ ------------------------fv COMMISSIONEROF Promulgated: f_. )<1~ }YfJ INTERNAL REVENUE, ~e:~~~~e~~ x - - - - - - - - - - - - - - - - RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is respondent's Motion for Reconsideration (Re: Decision promulgated 15 July 2025), filed on August 13, 2025, with petitioner's Opposition (To the Motion for Reconsideration dated 7 August 2025), filed on August 29, 2025, assailing this Court's Decision, dated July 15, 2025, which granted the instant Petition for Review. The Motion is a near-verbatim rehash of the arguments that respondent raised in his Answer, 1 filed on November 3, 2023. All such arguments were already addressed in the assailed Decision and need not be discussed again.2 The Motion, as such, is left without merit, revealing no compelling reason to disturb Our ruling. Rollo,pp. 133-138. Roque v. Commission on Election, G.R. No. 188456 (Resolution), February I0, 201 0; Shangri-La International Hotel Management, Ltd. v. Developers Group a,(Companies, Inc., G.R. No. 159938 (Resolution), January 22, 2007; Ortigas and Company Limited Partnership v. Velasco, G.R. Nos. I09645 & 112564 (Resolution), March 4, 1996.

.; RESOLUTION ,CTA CASE NO. 11271 � Page 2 of2 ACCORDINGLY, respondent's Motion for Reconsideration (Re: Decision promulgated 15 July 2025), filed on August 13, 2025, is hereby DENIED for lack of merit. The assailed Decision, dated July 15, 2025, is AFFIRMED. SO ORDERED. MARIA WE CONCUR: ~.~ ~ ' - - MA. BELEN M. RINGPIS-LIBAN Associate Justice c~t. Associate Justice