COMMISSIONER OF INTERNAL REVENUE v. SOUTH COTABATO 1 ELECTRIC COOPERATIVE INC.,

REPUBLIC OF THE PHILIPPINES Court of Tax Appeals QUEZON CITY En Bane COMMISSIONER OF INTERNAL CTA EB NO. 3001 REVENUE, (CTA Case No. 10937) Petitioner, Present: RINGPIS-LIBAN, PJ, BACORRO-VILLENA, MODESTO-SAN PEDRO, -versus- REYES-FAJARDO, CUI-DAVID, FERRER-FLORES, ANGELES, TESTON, and SOUTH COTABATO 1 ELECTRIC CENTENO-DIJAMCO,JJ. COOPERATIVE, INC., Respondent. Promulgated: SEP 2 3 2026 X ----------------------------------------------------------------------- ---------------- X RESOLUTION MODESTO-SAN PEDRO, J.: For the Court's resolution is petitioner's Motion for Reconsideration (Re: D ecision promulgated on 03 D ecember 2025), filed on December 17, 2025, with respondent' s Comment/Opposition thereto, filed on January 26, 2026. The Motion is bereft of merit. Petitioner raises two arguments: ( 1) there was no valid administrative protest to the assessment; and (2) since the assessment was not protested, petitioner validly issued the Preliminary Collection Letter ("PCL"), so his right to collect the assessed amount has not prescribed. Both arguments, however, completely miss the point of Our ruling. For (1), petitioner still does not show how the procedural rules for judicially protesting an assessment is relevant to this case, which does not involve a judicial protest to an assessment. As for (2), petitioner merely claims that the issuance of the PCL initiated collection efforts. He completely fails to acknowledge

RESOLlTIO~ CT A !:B No. 3001 (CTA Case No. 10937) Page 2 of3 or address Our discussion of the PCL' s contents, however, which is what actually lead Us to find that the PCL did not initiate collection efforts. For having little to no connection to the actual reasons behind Our ruling, the Motion deserves scant consideration. FOR THESE REASONS, petitioner's Motion for Reconsideration (Re: Decision promulgated on 03 December 2025}, filed on December 17, 2025, is hereby DENIED for lack of merit. The Decision, dated December 3, 2025, is AFFIRMED. SO ORDERED. MARIA RO"(EN Associate stice WE CONCUR: Lc-. ~ "---· MA. BELEN M. RINGPIS-LIBAN Presiding Justice ~ . BACORRO-VILLENA ~ ~ f. ~ -taja-..t-4, MARIAN IVY F .CkEYES-~AJARDO Associate Justice /t4eufU1;;L__ LANEE S. CUI-DAVID Associate Justice

R[SOUTIO'\ CTA EB '\Jo. 300! (CTA Case Nn_ 10937) Page .3 of3 ~,q ...,-y_-.~ CORA~N G.(JtERRE-FL ES Associate Justice HENRJZNGELES Associate Justice e Justice Associate Justice