CIR v. Costner Trading Corporation
CTA EB NO. 2322
August 22, 2022
Doctrine:
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.
Facts:
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.
Issues:
Whether or not the motion for reconsideration should be granted.
Ruling:
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.