FIRST DIVISION
[G.R. No. 245514. June 17, 2019.]
PNOC MANAGEMENT AND DEVELOPMENT CORPORATION, petitioner, vs.COMMISSIONER OF INTERNAL REVENUE, respondent.
NOTICE
Sirs/Mesdames :
Please take notice that the Court, First Division, issued a Resolution datedJune 17, 2019which reads as follows:
"G.R. No. 245514 (PNOC Management and Development Corporation v. Commissioner of Internal Revenue). — The petitioner's motion to admit petition for review on certiorari with manifestation, praying that thereto attached petition for review on certiorari be admitted and given due course for reasons stated therein is DENIED for being filed out of time, due date being February 16, 2019.
The Court resolves to DENY the petition for being filed beyond the reglementary period and for failure to show that the Court of Tax Appeals (CTA) En Banc committed any reversible error in its assailed ruling. The CTA En Banc correctly affirmed the CTA Division's findings that, (1) Site 2A is an ordinary asset whose sale is subject to value-added tax; (2) petitioner was not denied of due process; and (3) petitioner's proposal to include its payments in support of its application for compromise in the computation of its remaining tax liability is untenable and premature. HTcADC
WHEREFORE, premises considered, the petition is DENIED. The Decision dated February 19, 2018 and Resolution dated January 24, 2019 of the Court of Tax Appeals in CTA EB No. 1486 are hereby AFFIRMED.
SO ORDERED."
Very truly yours,
(SGD.) LIBRADA C. BUENADivision Clerk of Court