Lapanday Agricultural & Development Corp. v. Commissioner of Internal Revenue

EN BANC [C.T.A. EB CASE NO. 2174. January 4, 2021.] (C.T.A. Case No. 9965) LAPANDAY AGRICULTURAL & DEVELOPMENT CORPORATION , petitioner , vs. COMMISSIONER OF INTERNAL REVENUE , respondent . RESOLUTION For resolution is petitioner's " Motion for Reconsideration (of the Decision dated 22 September 2020) " filed on October 14, 2020, without respondent's comment thereon. 1 In his Motion, petitioner prays that the Court: (i) reverse and set aside the assailed Decision dated September 22, 2020 as well as the assailed Resolutions of the Court in Division dated July 30, 2019 and October 15, 2019; and, (ii) direct respondent to refund or issue a tax credit certificate in favor of petitioner in the amount of P13,132,450.07. The dispositive portion of the assailed Decision reads: " WHEREFORE , in light of the foregoing, Lapanday Agricultural & Development Corporation's Petition for Review filed on November 19, 2019 is hereby DENIED for lack of merit. The Resolutions dated July 30, 2019 and October 15, 2019 are hereby AFFIRMED . HTcADC SO ORDERED. " Acting on petitioner's Motion, the Court notes that no new substantial arguments have been adduced to warrant the reconsideration sought. Petitioner merely raised matters which the Court has thoroughly passed upon in the assailed Decision. Accordingly, the Court finds no cogent reason to reverse or modify the assailed Decision. WHEREFORE , in light of the foregoing, petitioner's " Motion for Reconsideration (of the Decision dated 22 September 2020) " filed on October 14, 2020 is hereby DENIED for lack of merit. SO ORDERED. Roman G. Rosario, P.J., Juanito C. Castaeda, Jr., Erlinda P. Uy, Ma. Belen M. Ringpis-Liban, Catherine T. Manahan, Jean Marie A. Bacorro-Villena and Maria Rowena Modesto-San Pedro, JJ. , concur. Footnotes 1. Resolution dated November 24, 2020.