cta_resolution CTA Case No. EB 979EB 979 2015-02-17

UNITED COCONUT PLANTERS BANK, v. COMMISSIONER OF INTERNAL REVENUE

REPUBLIC OF THE PHILIPPINES COURT OF TAX APPEALS QUEZON CITY EN BANC UNITED COCONUT C. T.A. EB No. 979 (C .T .A. Case No. 7903) PLANTERS BANK, Present : Petitioner, DEL ROSARIO ,PJ; -versus- CASTANEDA, JR., BAUTISTA, COMMISSIONER OF UY, INTERNAL REVENUE, CASANOVA, Respondent. FABON -VICTORINO, MINDARO- GRULLA, COTANGCO-MANALASTAS and RINGPIS-LIBAN, JJ. Promulgated : FEB 17 1015 X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _, r::.2 r'..�l>-/-' ~-� - - - - - -X RESOLUTION Fabon-Victorino, J.: For resolution is the Motion for Reconsideration dated October 10, 2014 filed by petitioner United Coconut Planters Bank, assailing the Decision promulgated on September 3, 2014, the dispositive portion of which reads: WHEREFORE, the Petition for Review j dated January 24, 2013 filed by petitioner United Coconut Planters Bank is hereby DENIED, for lack of merit. SO ORDERED.

Resolution C.T.A. EB No. 979 The relief sought by respondent is anchored on the following grounds: A. The petitioner's claim for issuance of TCC was filed within the period prescribed by law. B. Petitioner's unutilized creditable withholding taxes are duly substantiated by documentary evidence. C. The income upon which the subject unutilized creditable withholding taxes withheld were declared as part of petitioner's gross revenue in its Annual Income Tax Return for calendar year 2006. Despite the opportunity granted, respondent failed to file her comment or register any objection to petitioner's motion, per Records Verification dated December 2, 2014. After going over petitioner's allegations in the subject Motion for Reconsideration, the Court finds that it is but a restatement, if not a replica, of its previous pleadings filed with the Court. The issues and the arguments raised therein have already been amply addressed and sufficiently discussed in the assailed Decision of September 3, 2014, specifically from pages 11 to 22 thereof. In the absence of any new or significant if not compelling grounds in petitioner's plea for reconsideration, additional disquisition is superfluous. WHEREFORE, the Motion for Reconsideration dated October 10, 2014 filed by petitioner United Coconut Planters Bank is hereby DENIED, for lack of merit. SO ORDERED. R. FABON-VICTORINO

Resol u tio n C.T.A. EB No. 979 Pag e 3 of 3 We Concur: Presiding Justice ~~h e. ~~~~ . ~ JtfANITO c. CASTANEDA, JR. CAESAR A. CASANOVA Associate Justice Associate Justice - ER~.UY Associate Justice f'.'.d ~rN~ M~~ .. G~ ~~ ~ - CrELi'T'Q N. MINDARO-GRULLA AMELIA R. COTAN...,GC0-MANALASTAS Associate Justice Associate Justice ~� ~ ~L.:. MA. BELEN M. RINGPIS-LIBAN Associate Justice

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