Manulife Data Services, Inc. v. Commissioner of Internal Revenue

SPECIAL THIRD DIVISION [C.T.A. CASE NO. 7913. August 6, 2013.] MANULIFE DATA SERVICES, INC. , petitioner , vs . COMMISSIONER OF INTERNAL REVENUE , respondent . [C.T.A. CASE NO. 7977. August 6, 2013.] MANULIFE DATA SERVICES, INC. , petitioner , vs . COMMISSIONER OF INTERNAL REVENUE , respondent . [C.T.A. CASE NO. 8018. August 6, 2013.] MANULIFE DATA SERVICES, INC. , petitioner , vs . COMMISSIONER OF INTERNAL REVENUE , respondent . RESOLUTION BAUTISTA , J p : For resolution are the following: SCDaHc 1. Petitioner's "Motion for Partial Reconsideration (Re: Decision of 13 June 2013)" filed on July 3, 2013; 2. Respondent's "Motion for Partial Reconsideration (Re: Decision promulgated on 13 June 2013)" filed on July 4, 2013, as well as petitioner's "Comment/Opposition (Re: Respondent's Motion for Reconsideration dated 02 July 2013);" and 3. Petitioner's "Urgent Motion for Extension" filed on July 25, 2013. The above cited pleadings were filed by the parties in relation to the Decision of the Court dated June 13, 2013, which partially granted the Petition for Review filed by petitioner Manulife Data Services, Inc., ordering respondent to issue a Tax Credit Certificate in the reduced amount of Four Million Eight Hundred Ninety Eight Thousand Fifty Three and 35/100 pesos (Php4,898,053.35) for its unutilized/unapplied input VAT for taxable year 2007. On July 9, 2013, the Court issued a Resolution ordering both parties to file their respective Comments to the Motions filed. On July 25, 2013, petitioner filed an "Urgent Motion for Extension" praying for an additional period of ten (10) days from July 25, 2013 or until August 4, 2013, to submit its Comment. On July 29, 2013, petitioner filed its "Comment/Opposition (Re: Respondent's Motion for Reconsideration dated 02 July 2013)." After a careful study of the issues raised by the parties, the Court finds no merit in both the "Motion for Partial Reconsideration (Re: Decision of 13 June 2013)" and "Motion for Partial Reconsideration (Re: Decision promulgated on 13 June 2013)," filed respectively by petitioner and respondent. cHSTEA All the issues raised by both parties in their respective Motions were already passed upon by the Court in the Decision dated June 13, 2013. The parties did not raise any new argument that would merit reconsideration of the said Decision. WHEREFORE , petitioner's "Motion for Partial Reconsideration (Re: Decision of 13 June 2013)" and respondent's "Motion for Partial Reconsideration (Re: Decision promulgated on 13 June 2013)" are hereby DENIED for lack of merit. SO ORDERED . (SGD.) LOVELL R. BAUTISTA Associate Justice Amelia R. Cotangco-Manalastas, J., concurs.