SYNDTITE CONSTRUCTION CORPORATION v. COMMISSIONER OF INTERNAL REVENUE

CTA Form No. 8 (For DCC) 111111111111111111111111111 11111 1111111111111111111111111 11111 11111 11111 11111111 25-0004 76-0003 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY FIRST DIVISION CTA CASE NO. 11964 SYNDTITE CONSTRUCTION CORPORATION, Petitioner, - versus- NOTICE OF RESOLUTION ; COMMISSIONER OF INTERNAL REVENUE, Respondent. To: GALlAS & RIVERA LAW OFFICES 3rd Floor, Prestige Tower F. Ortigas Jr. Road, Ortigas Center Pasig City GREETINGS: You are hereby notified by these presents that on July 11, 2025, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, July 14, 2025.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS Quezon City FIRST DIVISION SYNDTITE CONSTRUCTION CTA CASE NO. 11964 CORPORATION , Members: DEL ROSARIO, P.J. , Chairperson, Petitioner, BACORRO-VILLENA, and CUI-DAVID, JJ. -versus- - -- - - - - --- - X COMMISSIONER OF INTERNAL REVENUE , Respondent. On 29 May 2025, petitioner Syndtite Construction Corporation (petitioner/SCC) filed a Petition for Review, praying that this Court declare void the assessment issued against it for deficiency Value- Added Tax (VAT) covering the period from 01 January 2017 to 30 June 2017. Per Records Verification dated 02 June 2025, this Court's Judicial Records Division (JRD ) certified that petitioner failed to submit an email or soft copy of the instant Petition for Review within twenty- four (24) hours from the filing of the hard or paper copy on 29 May 2025, in violation of Section 2, paragraph 21 of En Bane Resolution No. 8-20242 , adopting A .M. No. 10-3-7-SC and A.M. No. 11-9-4-SC3 (eFiling Guidelines). 2. Manner oftransmillal.- The PDF copies must be rransmirted by litigants and coutt users to the official e-mail addresses: When the primary manner of filing is th rough personal filing, by registered mail, or by accredited courier. in accordance with Rule 13. Section 3(a), 3(b), or 3(c) of the 2019 Amendments to the 1997 Rules of Civil Procedure. ten ( I0) paper copies for En Bane cases, and six (6) paper copies for initiatoty pleadings or four (4) paper copies for subsequent pleadings for Division cases, shall be filed. The PDF copies must be transmirted within twenty-four (24) hou rs from such filing of paper copies; otherwise, tlt e pleading or court submission sitall be deem ed as notfiled. Guidelines on Submission of Electronic Copie of Pleadings and Other Court Submissions Before the Court of Tax Appeals Pursuant to A. M. No. I0-3-7-SC and A.M. 11-9-4-SC. RE: GU IDELI NES ON SU BMI SS ION OF ELECTRON IC COPI ES OF PLEADINGS AND OTHER COU RT SU BM ISSIO S BEl G FILED BEFORE THE LOWER COURTS PURSUANT TO THE EFF ICIE T USE OF PAPER RULE/MOVING TOWARDS DI GITAL COU RTS:

RESOLUTION CTA CASE NO. 11964 Syndtite Construction Corporation v. Commissioner of Internal Revenue Page 2 of3 X-------------------- ------------------------- ---------- X In addition to this Court's adoption of the eFiling Guidelines through En Bane Resolution No. 8-2024, the Supreme Court's Resolution dated 26 November 2024 on Rule 13-A of the Rules of Court (ROC), as amended, or the "Interim Rule on the Electronic Filing and Service of Pleadings Judgment, and Other Papers in Civil Cases" (Interim Rule), which took effect on 01 December 2024, provides that no court shall act upon an initiatory pleading unless it is accompanied by an electronic transmitta l. If such electronic transmittal is not completed within the prescribed 24-hour period, the initiatory pleading shall be deemed not filed , to wit: SECTION 3. Manner of filing of complaints and other initiatory pleadings. -The filing of complaints and other initiatory pleadings shall be done by : a. Submitting personally the original paper, plainly indicated as such, to the court; b. Sending the paper by registered mail; or, c. Sending the paper by accredited courier. After the complaint or initiatory pleading has been filed through any of the three modes provided in the first paragraph of this Section, the filing party shall subsequently email the complaint or initiatory pleading in digital file format to the court. Digital copies of the additional accompanying documents of the complaint or initiatory pleading , such as annexes, appendices, or exhibits, shall likewise be emailed . The electronic transmittal ofthe complaint or initiatory pleading and the accompanying documents must be made within 24 hours from the completeness of the primary mode of the complaint or initiatory pleading's filing. The term "digital file format," when used to refer to plead ings, papers, and other documents, shall mean the portable document format. No court shall act upon any complaint or initiatory pleading unless the latter's filing is accompanied by the electronic transmittal required in the third paragraph of this Section. If the electronic transmittal is not completed before the period, the complaint or initiatory pleading shall be deemed not filed, regardless of the completeness of the primary mode of its filing .4 COM PONENT ONE: TRAN SIT ION TO EL ECTRON IC FI LING AND SERV ICE OF PLEADINGS, MOTIONS AND OTHER DOCUMENTS AS WELL AS D IGITAL SE RVICE OF ALL ORDER S IN CIV IL CA SES. Emphasis and underscoring supplied.

RESOLUTION CTA CASE NO. 11964 Syndtite Construction Corporation v. Commissioner of Interna l Revenue x-------------------------------------- -- ------------ --- x Accordingly, for petitioner's failure to comply with the electronic transmittal requirement within the prescribed 24-hour period, as mandated under En Bane Resolution No. 8-2024 in relation to the Interim Rule, the instant Petition for Review dated 29 May 2025 is hereby DEEMED NOT FILED. SO ORDERED. Presiding Justice ON OFFICIAL BUSINESS LANEE S. CUI-DAVID Associate Justice