INSPIRO RELIA GLOBAL SHARED SERVICES, INC. REGIONAL OPERATING HEADQUARTERS v. COMMISSIONER OF INTERNAL REVENUE

CTA Form No.8 (For DCC) 1111111111111111111111 11111 11111111111111111111 1111111111 11111 111111111111111111 22-000262-0068 REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION CTA CASE NO. 10874 INSPIRO RELlA GLOBAL SHARED SERVICES, INC. REGIONAL OPERATING HEADQUARTERS, Petitioner, NOTICE OF RESOLUTION -versus- COMMISSIONER OF INTERNAL REVENUE, Respondent. To: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo Street, Legazpi Village Makati City ATTY. ALBERT C. ARPON ATTY. CARL FITRI A. HUSSIN ATTY. DYRENE MARAS. ROSARIO Bureau of Internal Revenue-Revenue Region No.8A 36th Floor, Export Bank Plaza Building 313 Sen. Gil Puyat Avenue cor. Chino Roces Avenue Makati City EMMANUEL C. ALCANTARA AND ASSOCIATES LAW OFFICES 5th Floor, SGV I Building 6760 Ayala Avenue 1226 Makati City GREETINGS: You are hereby notified by these presents that on July 8, 2026, a Resolution was rendered in the above-entitled case, copy of which is attached hereto. Quezon City, Philippines, July 9, 2026.

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY SPECIAL FIRST DIVISION INSPIRO RELlA GLOBAL CTA CASE NO. 10874 SHARED SERVICES, INC. Members: REGIONAL OPERATING HEADQUARTERS, Petitioner, -versus- BACORRO-VILLENA, Acting Chairperson, and CUI-DAVID, JJ. COMMISSIONER OF Promulgated: INTERNAL REVENUE, Respondent. :JUL 082026 ; y:OOPM I C X - - - - - - - - - - - - - - - - - - - - - - - - - . - -=> - - - - - - - - - - -X RESOLUTION CUI-DAVID, J.: For resolu tion is respondent's Motion for Partial Reconsideration (Re: Decision dated 18 March 2026) [Motion for Partial Reconsideration], filed on April 8, 2026, with petitioner's Comment/Opposition, filed on April 16, 2026. Respondent seeks reconsideration and reversal of the Decision dated March 18, 2026 (the assailed Decision), which partially granted the petitioner's Petition for Review. The dispositive portion of the assailed Decision reads: WHEREFORE, in light of the foregoing, the present Petition for Review (of Petitioner Inspire Relia Global Shared Services, Inc. - Regional Operating Headquarters) is PARTIALLY GRANTED. Accordingly, respondent is ORDERED to REFUND or ISSUE A TAX CREDIT CERTIFICATE in favor of petition er in the total amount ofP37,322,9 19.46, representing its excess and unutilized creditable withholding taxes for taxable year 2019. SO ORDERED.

RESOLUTION CTA Case No. 10874 Inspire Relia Global Shared Services, Inc. Regional Operating Headquarters v. Commissioner of Internal Revenue x-----------------------------------------------------------------------------------------------------x In his Motion for Partial Reconsideration, respondent argues that petitioner failed to substantiate its prior years' excess tax credits that were utilized to settle its income tax due for taxable year (TY) 2019 . Thus, it failed to establish that the creditable taxes withheld (CWT) at issue in this case remain unutilized. Respondent likewise reiterates that a tax refund, being in the nature of a tax exemption, must be construed strictissimijuris against the taxpayer claiming it. On the other hand, petitioner avers that the assailed Decision has already squarely addressed and resolved the issue of its entitlement to the subject refund, having categorically found that it has complied with all the requisite conditions. It further maintains that, for the covered period, the income tax overpayment of P118,875 ,268.00, and the CWT forTY 2019 of P38,752,049.00 remained excess and unutilized and, thus, constitutes the subject present claim for refund. These amounts were independently verified by the Independent Certified Public Accountant and were fully substantiated and properly attributable to the income declared for TY 2019. Petitioner also clarified that the present claim pertains only to the CWT forTY 2019, which remained excess and unutilized. Moreover, petitioner contends that the validity of its tax credits, including those carried over from previous years, was effectively examined and not disallowed by the Bureau of the Internal Revenue, as evidenced by the Judicial Affidavit of Revenue Officer Esmail G. Garim, respondent's witness. The instant Motion for Partial Reconsideration must fail. After a judicious evaluation of the parties' submissions, the Court finds no cogent reason to modify or overturn the assailed Decision. The arguments raised by respondent have already been thoroughly considered, resolved, and addressed in the assailed Decision. In the absence of any new or significant grounds warranting reconsideration, the Court's conclusion in the assailed Decision, that petitioner complied with the three requisites for the refund of its excess and unutilized CWT forTY 2019, but only in the reduced amount of P37,322,919.46, stands. Respondent primarily contends that petitioner failed to substantiate its prior-year excess tax credits used to settle its income tax liability for TY 2019. However, it bears stressing \1

RESOLUTION CTA Case No . 10874 Inspiro Relia Global Shared Services, Inc. Regional Operating Headquarters v. Commissioner of Internal Revenue X-----------------------------------------------------------------------------------------------------X that, with regard to prior years' excess tax credits, the submission of a taxpayer's annual income tax return (ITR) for the immediately preceding taxable period is sufficient to support the carryover of such credits to the current taxable period. Furthermore, the Supreme Court, in Commissioner of Internal Revenue v. Philippine National Bank, clarified that "the presentation of the annual ITR would suffice in proving that prior year's excess credits were not utilized for the taxable year in order to make a final determination of the total tax due."1 Notwithstanding the foregoing, petitioner correctly points out that the present claim for refund pertains to the CWT accumulated during the four quarters of TY 20 19, in the total amount of P38,752,049.00,2 and not to prior years' excess tax credits. With respect to this amount, the Court sustains its finding that petitioner is entitled to a partial refund. WHEREFORE, premises considered, respondent's Motion for Partial Reconsideration (Re: Decision dated 18 March 2026) is hereby DENIED for lack of merit. SO ORDERED. I CONCUR: Associate Justice ( ' G. R. No. 212699, March 13, 20 19 [Per J. Reyes, J. Jr, Second Division]. Exhibit " P-1 5'', Schedule 8, Docket- Vol. II, p. 7 19.