Tullett Prebon (Philippines), Inc. v. Commissioner of Internal Revenue

EN BANC[C.T.A. EB CASE NO. 2143. November 18, 2020.](C.T.A. Case No. 9320)TULLETT PREBON (PHILIPPINES), INC., petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.DECISIONUY, J p:Before the Court En Banc is a Petition for Review filed on October 11, 2019 1 by Tullett Prebon (Philippines), Inc., against the Commissioner of Internal Revenue, praying to reverse and set aside the Decision dated April 12, 2019 and Resolution dated September 4, 2019, 2 both rendered by the Special Third Division of this Court (Court in Division) in CTA Case No. 9320, entitled "Tullett Prebon (Philippines), Inc., Petitioner, vs. Commissioner of Internal Revenue, Respondent." The dispositive portions thereof respectively read: Decision dated April 12, 2019:"WHEREFORE, premises considered, the Petition for Review is hereby DENIED.SO ORDERED."Resolution dated September 4, 2019:"WHEREFORE, finding no compelling reasons to allow the presentation of additional evidence and to reverse or modify the ruling of this Court in the assailed Decision, petitioner's Motion for Reconsideration with Motion for Leave of Court to Present Additional Evidence is DENIED for lack of merit.SO ORDERED."THE FACTSPetitioner Tullett Prebon (Philippines), Inc....