CIR v. Costner Trading Corporation


CIR v. Costner Trading Corporation

CTA EB NO. 2322

August 22, 2022


The Supreme Court denied respondent's

Motion for Reconsideration for being a mere reiteration of their previous

arguments, and for failure to raise matters substantially plausible or

compellingly persuasive to warrant the reversal of the assailed Decision.


In the instant motion, petitioner avers that the Court erred in cancelling

and setting aside the deficiency VAT assessment issued against respondent for

the period from January to June 2013; that the Formal Assessment Notice

(FAN) is valid because it contains legal and factual bases; and that respondent

failed to inform the Revenue District Officer of Revenue District No. 47 in

East Makati that it has changed its office address from Revenue District Office

(RDO) No. 47 in East Makati to RDO No. 29 in Manila in accordance with the

requirement of Revenue Regulations No. 12-85.


Whether or not the motion for reconsideration should be granted.


No.  A careful and closer look at the arguments raised by petitioner in his

present motion reveals that the grounds relied upon and the matters raised

therein are mere restatements of his previous arguments. All these matters were

already considered and extensively discussed upon by the Court En Bane in the

assailed Decision.

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