Samsung SDS Global SCL Philippines Co., et al. vs. Commissioner of Internal Revenue

DECISION

COMMISSIONER OF INTERNAL

REVENUE, To:

Respondent.

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legazpi Village

Makati City

ATTY. FELIX PAUL R. VELASCO III ATTY. SYLVIA R. ALMA JOSE ATTY. AYESHA HANlA B. GUILING-MATANOG

Bureau of Internal Revenue

Room 703, Litigation Division, BIR National Office Building Sen. Miriam P. Defensor-Santiago Avenue Diliman, Quezon City

GALVEZ CARDINO PA YUMO LAW OFFICES

Unit 77B, A VR Building Beaterio Street, Intramuros

1002 Manila

GREETINGS:

You are hereby notified by these presents that on October 1, 2026, an Amended Decision was rendered in the above-entitled case, copy of which is attached hereto.

Quezon City, Philippines, October 1, 2026.

Page 1 of 1

REPUBLIC OF THE PHILIPPINES

COURT OF TAX APPEALS

QUEZON CITY

SPECIAL FIRST DIVISION

SAMSUNG SDS GLOBAL

SCL PHILIPPINES CO., LTD. INC., Petitioner, -versus -

COMMISSIONER OF

INTERNAL REVENUE, Respondent.

CTA CASE NO. 11129

Members:

BACORRO-VILLENA, Acting Chairperson, and CUI-DAVID, JJ.

Promulgated:

SEP 2 9 2026; f)$P/JJ ..

X - - - - - - - - - - - - - - - - - - - - - - - - - - - - t:- .:-:;:r - - - - - - - - - - - - - - - - X

AMENDED DECISION

CUI-DAVID, J.:

Submitted for the Court's resolution is petitioner's Motion for Reconsideration (Re: Decision dated 22, [sic] January 2026) [Motion], mailed on February 13, 2026, and received by the Court on February 20, 2026, with respondent's

Comment and Opposition [Re: Petitioner's Motion for

Reconsideration (Re: Decision dated 22 January 2026)], filed on March 25, 2026.

On January 22, 2026, the Court promulgated a Decision denying petitioner's claim for refund of unutilized creditable withholding taxes (CWTs) of P30,208,50 1.64, for failure to sufficiently establish that the income payments from which the claimed CWTs were withheld were included in its gross income as reported in its Annual Income Tax Return (AITR) for calendar year (CY) 2020. The dispositive portion of the assailed Decision reads:

"WHEREFORE, in light of the foregoing considerations, the present Petition for Review is DENIED for lack of merit.

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co. , Ltd. Inc. v. Commissioner of Internal

Revenue

In its Motion, petitioner assails the Court's finding that it failed to establish that the income payments upon which the claimed CWTs were withheld were reported as part of its gross income in its AITR, as such, it failed to satisfy the third requisite for the entitlement of its claim, i.e., that the income upon which the taxes were withheld must have been included in the income tax return of the recipient.

Petitioner

recalls that the amount totaling P1 ,449,533,227.67 as income payments was disallowed by the Court since it failed to prove that the amount was reported as part of its gross income based on: the SAP Extracted Sales lacked the sum totals (the SAP total revenues could not be confirmed); and, the income tracing schedules (referencing Exhibits "P-38" and "P-39") prepared by the Independent Certified Public Accountant (ICPA) did not specifically identify the sub-marked exhibits referenced therein, thereby preventing the confirmation and verification of the amounts traced and included in the schedules. Petitioner asserts that the Court's Decision imposed extra-statutory procedural requirements for income inclusion which it argues is contrary to the National Internal Revenue Code (NIRC) of 1997, as amended, and controlling Supreme Court doctrine on the matter. Petitioner claims that the NIRC of 1997, as amended, does not prescribe a specific accounting- report format or exhibit labeling scheme as a condition for due course. Citing the case of Tullett Prebon (Philippines), Inc. v. Commissioner of Internal Revenue, 1 petitioner states that there is no prescribed evidence to prove income inclusion and that the standard quantum is preponderance of evidence. Petitioner contends that the proper judicial approach is to evaluate the evidence on record cumulatively-not to deny the entire claim based on perceived insufficiency in one report's formatting or one cross-referencing style.

Thus, petitioner submits that the Court should allow clarificatory submissions where the crux of denial rests on the alleged insufficiency of cross-references, and that, to assist in the verification, the ICPA submitted to this Court a Letter dated February 13, 2026 describing the procedures performed 1 G.R. No. 257219, July I 5, 2024 [Per J. Dimaampao, Third Division].

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

in tracing the income payments subject to CWT to the gross income reported in petitioner's AITR for CY 2020.2 On the other hand, respondent maintains that the Court correctly ruled that petitioner failed to establish that the income payments amounting to Pl,449,533,227.67, from which the claimed CWTs arose, were included in its gross income for CY 2020. Hence, respondent insists that petitioner failed to satisfy the third requisite for a claim for refund of excess unutilized CWTs.

Respondent further reiterates his position that petitioner failed to exhaust administrative remedies before elevating the case to the Court. Consequently, respondent insists that the present Petition for Review was prematurely filed considering that petitioner's administrative claim for refund of CWT remained pending investigation and evaluation before the Bureau of Internal Revenue (BIR).

After due consideration, the Court finds partial merit in petitioner's Motion.

As previously discussed, the third requisite for a valid claim for refund or tax credit of excess unutilized CWTs requires proof that the income upon which the taxes were withheld was included in the return of the payee or recipient. Correspondingly, for its CWT refund claim to prosper, it is incumbent upon petitioner to prove that the income payments corresponding to the claimed CWTs were indeed declared as part of its income in its AITR for CY 2020. To recall in the assailed Decision, the Court considered and examined petitioner's Annual Financial Statements (AFS), AITR, and other relevant documents, together with the submitted ICPA Report and its related schedules, as follows:

1. AFS for CY 2020;3

2. AITR for CY 2020;4

3. SAP Extracted Sales;s 4 . Cello System Extracted Data;6 2 "Letter in response to the Honorable Court 's decision in denying the Petitioner 's Petition for Review on its application for refund of P30,208,502.00. representing alleged unutilized creditable withholding taxes (CWTs) for calendar year 2020" dated February 13, 2026, attached in petitioner's Motion for Reconsideration. 3 Exhibit "P50", Note 13, Page 23 of 47, USB (Exhibit "P-26-2"). 4 Exhibit "P-5-4", Line 27, Docket- Vol. I, p. 69. s Exhibits "P-36-1" to "P-36-14". USB (Exhibit "P-26-2"). 6 Exhibits "P-38-1 ,. to "P-38-12" and "P-39-1 " to "P-39-8", USB (Exhibit "P-26-2").

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

5. Samsung Electronics Philippines Co. (SEPCO)-Provided Schedule of Income Payments from which Taxes were Withheld;7

6. Sam sung Electro-Mechanics Philippines Corporation (SEMPHIL)-Provided Schedule of Income Payments from which Taxes were Withheld;B

7. Cello System Extracted Freight Billing Invoices for SEPCQ;9

8. Cello System Extracted Freight Billing Invoices for SEMPHIL; Io

9. Schedules of income payment tracing from SEPCO- provided schedule to the Cello System;ll and

10. Schedules of income payment tracing from SEMPHIL- provided schedule to the Cello System.12 Upon evaluation of the foregoing documents, the Court found that the revenues reported in petitioner's AFS for CY 2020 in the amount of P2,627 ,090, 744.00 tallied with those reported in its AITR for the same year. The Court likewise took note of the ICPA's explanation regarding petitioner's use of the Cello Billing Management System (Cello System) for its logistics transactions.

However, in verifying the income payment tracing, the Court found that the SAP Extracted Sales, which contains the logistics revenues per SAP books and ranges Exhibits "P-36-2" to "P-36-14 ," did not reflect the calculated totals or summations for each, thus, preventing the confirmation of whether the amounts reflected therein corresponded to the alleged revenues of P2,625,573,211.32 purportedly carried over to the revenues reported in the AFS. The Court further observed that the ICPA's schedules of income tracing (Annexes 5-7 and 14-16) indicated only Exhibits "P-38" or "P-39 ," albeit actually ranging from Exhibits "P-38-1" to "P-38-12" and "P-39-1" to "P-39-8", as reference for the Cello System Extracted Data, to which the ICPA allegedly traced the income payments from the SEPCO and SEMPHIL- provided schedules, thereby, preventing the verification of the amounts traced by the ICPA to the Cello System Extracted Data.

7 Exhibit "P-40", USB (Exhibit "P-26-2"). 8 Exhibit "P-75", USB (Exhibit "P-26-2''). 9 Exhibits "P-37-1 " to "P-37-9", USB (Exhibit "P-26-2"). 10 Exhibits "P-69-1 " to "P-69-12", USB (Exhibit "P-26-2"). 11 Annexes 5, 6 and 7 of I CPA Report (Exhibit "P-26"), USB (Exhibit "P-26-2"). 12 Annexes 14, 15 and 16 of I CPA Report (Exhibit "P-26"), USB (Exhibit "P-26-2").

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

Clearly, the Court did not prescribe any particular format for the presentation of the income tracing, nor did it deny petitioner's claim outright merely because of the absence of sum totals and specific exhibit sub-references, without considering the relevant supporting documents presented. Rather, the conclusions reached in the Decision were based on the evidence presented by petitioner in support of its claim. No particular document or prescribed format was required to establish the income payment tracing. The Court duly examined the relevant supporting documents and schedules to determine whether the income tracing performed by the ICPA could be independently verified.

Significantly, substantiating the CWTs is a requirement separate and distinct from income tracing. Thus, even if the CWTs amounting to P30,208,502.00 were found to have been duly substantiated, petitioner was still required to establish that the corresponding income payments were included in the gross income reported in its AITR. Accordingly, the !CPA's findings on income tracing could not simply be accepted without sufficient supporting information that would enable the Court to verify them independently. Moreover, the Court's requirement that the relevant schedules reflect their sum totals and specific exhibit references does not amount to prescribing a particular form of evidence or manner of presentation to establish income inclusion. What the Court required-and what petitioner initially failed to provide-was sufficient information to enable the verification of its claim. The sum totals merely represent the aggregate amounts reflected in the submitted schedules and should have been indicated by the !CPA to support its conclusion that such schedules accounted for the alleged revenues of P2,625,573,211.32. Likewise, the specific exhibit sub-markings merely identify the precise portions of the Cello System Extracted Data to which the !CPA allegedly traced the corresponding amounts. If the amounts were indeed traced to such data, the specific supporting exhibits should have been clearly identified.

To address the foregoing deficiencies, petitioner submitted the !CPA's explanation and clarification of the procedures employed in tracing the income subject to CWT to the gross income reported in petitioner's AITR for CY 2020, as

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

set forth in the !CPA's letter dated February 13, 2026. 13 Accompanying the letter was a USB dated February 20, 2026, containing the SAP Extracted Sales14 and the Cello System Extracted Data, l S now reflecting the corresponding sum totals, as well as the schedules of income tracing (Annexes 5-7 and 14-16) containing detailed exhibit references. Considering that no new exhibits were offered and that the submissions merely clarify the evidence already on record, the Court shall consider the !CPA's explanation in resolving petitioner's Motion for Reconsideration. A perusal of the !CPA's findings16 shows that petitioner's total revenues per

SAP

books amounted to P2,627,090,744.21 , consisting of logistics and non-logistics revenues, as follows:

Particulars

Sales-Export Truck Transportation

Sales-Export Amount-Marine

Tran sportation

Sales-Export Amount-Air

Transportation

Sales-Import Amount-Marine

Transportation

Sales-Import Amount-Air

Tran s2ortation

Sales-Import Amount -Subcontractors

Sales-Warehou se-Storage Sales-Warehouse-Produ ct Mana gem ent Sales-Warehou se-VAS

Sales-Inland-Truck Transportation

Sales-Inland-Shipment

Sales-Inland-Air Transportation

Sales Revenue - Inland - Cou rier Total Logistics Revenu es

Non-logistics Revenues (Sales-Service-

PJ T)

Total Revenues per SAP Books

13 Docket - Vol. II, pp. 864-880.

14 Exhibits "P-36- 1" to " P-36- 14."

15 Exhibits "P-38-1" to "P-38-12" and "P-39-1" to "P-39-8".

Exhibit

Sum Totals

Numberl7

"P-36-2"

p 240,300.00

"P-36-3"

2,634,063.56

"P-36-4"

1,010,672,596.95

"P-36-5"

264,104,382.66

"P-36-6"

394,683,650.77

"P-36-7"

1,148,015.03

"P-36-8"

225,238,482.69

"P-36-9"

176,527,667.92

"P-36-10"

11,282,877.77

"P-36- 11"

465,996,466.66

"P-36-12"

33,970,682.75

"P-36-13"

37 '799' 166.46

"P-36-14"

1,274,858.10 2,625,573,211.32

P-36-1

1,517,532.89 P2,627 ,090, 744.21 16 Annex 3 of !CPA Report (Exhibit "P-26"), USB (Exhibit "P-26-2"); !CPA letter dated Feb. 13, 2026, Docket - Vol. II, pp. 875- 876.

17 USB dated February 13, 2026.

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

While the foregoing breakdown now confirms petitioner's revenues per

SAP

books, with th e total amount of P2,627,090,744.21 substantially tallying with the P2,627 ,090, 744.00 in revenues reported in petitioner's AFS and AITR for CY 2020, this alone does not establish compliance with the income-tracing requirement. Petitioner must still establish that the revenues recorded in its SAP books include the income payments amounting to P1,449,533,227.67, upon which the substantiated CWTs of P30,208,501.64 were withheld.

To support this, the ICPA validated that income payments from logistics services rendered to SEPCO and SEMPHIL, totaling P1,239,250,985.04 and corresponding to CWTs of P25,939,959.23, were traced to the Cello System and SAP books. The summary of the !CPA's findings is reproduced below, as follows: 18

Reference to

Traceable Revenue

Particulars

ICPA Reporti9

Amounts to Cello

CWT

System

Sales to SEPCO

a . Income payments per SEPCO- provided schedule are equal to the

Annex 5

P635,52 1,6 15.01 P13 ,851,929.05 amounts per Petitioner's Cello

System

b . Income payments per SEPCO- provided schedule are greater than

Annex 6

4,097,473.37 82,615.50 th e amounts per Petitioner's Cello

System

c. Income payments per SEPCO- provided schedu le are less than the

Annex 7

4,767, 184 .92 108,360.45 amounts per Petitioner's Cello

System

Subtotal

P644,386,273.30 p 14,042,905.00

Sales to SEMPHIL

a. Income payments per SEMPHIL- provided sch edule are equ al to the

Annex 14

117' 19 1,083.5020 2,343,82 1.6721 amounts per Petitioner's Cello

System

b . In come payments per SEMPHIL- provided sch edule are greater than

Annex 15

233,697,84 1.53 4 ,673,7 16.83 th e amounts per Petitioner's Cello

System

18 JCPA Report (Exhibit "P-26"), Docket - Vol. II, pp. 596 and 598. 19 USB dated February 13, 2026.

20 Apparently, the amount of !"151, 19 1,053.00 was erroneously indicated in the table under "Traceable Amounts to Cello System" column per ICPA Report summaries. Per Annex 14, only the amount ofP I1 7, 19 1,083.50 pertains to traced Revenues, and the remaining amount of 1"33,999,969.50 pertains to Pass-through Charges, which the ICPA admitted as not traced due to insufficiency of data (see ICPA Report [Exhibit "P-26"], Docket - Vol. !1, pp. 597 to 598).

21 2% of P II 7, 19 1,083.50 (following the CWT computation per Annex 14).

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

c. Income payments per SEMPHIL- provided schedule are less than the

Annex 16

243,975,786.71 4,879,515.73 amounts per Petitioner's Cello

System

Subtotal

P594,864, 711 . 74 p 11,897,054.23

Total

P1,239,250,985.04 P25,939,959.23 Upon further verification , however, the Court finds that, out of the P1,239,250,985.04 in income payments reported by the ICPA as having been traced, income payments amounting to P8,849,242.41, corresponding to CWTs of P176,984.84, were not shown to form part of the revenues recorded in the Cello System and SAP books and u ltimately carried over to the revenues reported in petitioner's AFS and AITR for CY 2020. The details of the amount of P8,849,242.41 and its corresponding CWTs of P176,984.84 are broken down hereafter as follows:

Per ICPA income tracing Per Court's furth er verification Revenues pe r

Traced to

Correspon ding

SEPCO-

Cello Syst em

Income

CWTof

Billin g provided

ICPA

Extracted

paym ent not in come Ref. No.

schedule traced

Report

Data/ SAP

Exhibit No.

t raced paym en t not

to Cello

Reference23

Ex t racted (c =a-b) t raced22 System.

Sales

(a) (b) "P-38-9" page 3;

30011 p 127,106.51

Annex 5

p 111,187.59 "P-36-11" page p 15,918.92 p 318.38 94 "P-38-11" page 30027 1,573.44

Annex 5

9 75.00 1;

598.44 11.97 "P-36-13" page 18 "P-38-9" page 98 29984 308,235.15

Annex 5

62,071 .35 &99;

246,163.80 4,923.28 "P-36-11" page 92 & 93 "P-38-9" page 3;

30069 3,667.15

Annex 5

298.15 "P-36-11" page 3,369.00 67.38 100 "P-38-9" page 30070 26,743.54

Annex 5

15,555.03 20;

11,188.51 223.77 "P-36 -1 1" page 100 & 101 "P-38-9" page 48 30074 3,956.47

Annex 5

2 ,370.07 &49;

1,586.40 31.73 "P-36- 11" page 101 "P-38- 11" page 30099 275,486.82

Annex 5

179,097.62 35;

96,389.20 1,927.78 "P-36- 13" page 32 & 33 "P-38-9" page 30196 5,808.95

Annex 5

4,422.11 110;

1,386.84 27.74 "P-36-11" page 22 Computed using 2% of the income payment, following the rate used in the Annexes. 23 USB dated February 13, 2026

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

Page 9 of 13

as ae Pe ae ae “P-38-9” pages 30217 7,481.31 Annex 5 4,211.13 | , Logie A190; 3,270.18 65.40 P-36-11” page 162 & 163 “P-38-9” page 110;

20,303.98 | «p.36-11" page “P-38-9” page 30218 27,343.94 | Annex 5 22,431.85], , 223 4,912.09 98.24 P-36-11” page 163 30249 22,051.77 Annex 5 1,747.79 34.96 211.60 138,224.92 “P-38-9” page 30293 162,555.37 Annex 5 a 19, 24,330.45 486.61 P-36-11” page 271 & 272 “P-38-9” page 30294 506,938.74 Annex 5 79,308.59 | , Fe 427,630.15 8,552.60 P-36-11” page 272 “P-38-9” page 30340 33,062.09 | Annex 5 580.04 ees 32,508.05 650.16 P-36-11” page 302 “P-38-9” page 30380 1,359.33 Annex 5 464.76 894.57 17.89 “P-36-11” page 321 “P-38-9” page 240 & 241;

“P-36-11” page 274 & 275 “P-38-9” page 30250 1,036.16 | Annex 5 L1G} 824.56 16.49 193;

30369 30,126.56 | Ames | | tien bee 30,126.56 602.53 207;

30332 362,102.42 146,466.72 215,635.70 4,312.71 “P-38-9” page 30439 358,242.36 | Annex 5 107,512.05 | ,. 2473 250,730.31 5,014.61 P-36-11” page 364 & 365 “P-38-9” page 30388 476,682.52 | Annex 5 166,984.09 |, ,.243: 309,698.43 6,193.97 P-36-11” page 322 & 323 “P-38-9” page 30438 714,751.47 | Annex 5 130,792.32 | , 246 & 247; 583,959.15 11,679.18 P-36-11” page 364 & 365 “P-38-11” page 30279 954.00| Annex 5 92.00 |, ..°%%, 862.00 17.24 P-36-13” page

OL

“P-38-11” page 30559 174,508.82 Annex 5 109,849.29 | , A 64,659.53 1,293.19 P-36-13” page 94 92;

“P-38-7” page 1;

30640 1,850,903.53 Annex 5 638,383.35 | , 4 1,212,520.18 24,250.40 P-36-9” page 3 “P-38-9” page 30794 243,542.23 | Annex 5 22,824.52 |,, ..1> 220,717.71 4,414.35 P-36-11” page 619

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal “P-36-11” page “P-38-9” page ov t3 “P-38-11” page 31164 392,073.94 Annex 5 3,116.04 388,957.90 7,779.16 120

Revenue

Page 10 of 13

34,893.31 697.87 556 “P-38-9” page 30693 79,367.92 | Annex 5 4,408.841,. . 14 74,959.08 1,499.18 P-36-11” page 558 119;

“P-36-13” page “P-38-11” page 31165 466,163.54 | Annex 5 251,714.60 |... 214,448.94 4,288.98 P-36-13” page 120 31352 2,343,092.55 1,687,108.95 | P738-7" page 2; 655,983.60 13,119.67 P-36-9” page 6 “P-38-9” page 31427 1,046,216.94 | Annex 5 224,463.30 | ,. , 8073 821,753.64 16,435.07 P-36-11” page 1119 & 1120 “P-38-9” page 31467 311,342.41 | Annex 5 175,136.59 | ,. , 808 136,205.82 2,724.12 P-36-11” page 1124 | 31564 | 2,150,455,99 | Annex 5 1,547,840,40 | P-38-7" page 2; 602,615.59 12,052.31 P-36-9” page 6 “P-38-9” pages 823, 923, 924, 926 to 928, cian {15,11330,| “mers sz rig.ey | S06, 10Gn ee 57,392.65 1,147.85 (not traced to “P- “P-38-11” page 31617 5,325.48 | Annex 5 958.12 | .. ..!293 5,067.36 101.35 P-36-13” page 130 | Subtotal | P13,763,991.95| | —«-—s_—«| P5,931,181.54| —————si|s« P7,832,810.41| P156,656.20 “P-39-1” page 1 & “P- a“ = page 8962 P 819,930.00 | Annex 14 P 60,350.00 | “P-36- - page 1 P 759,580.00 | P 15,191.60 & “P-36-11” page 173 9074 122,082.00 Fannext¢ | (ot pace gs 122,082.00 2,441.64 “P-39-3” pages 37, 44 & 45;

9277 25,300.00 | A7nex 14 21,100.00 4,200.00 84.00 9363 60,650.00 14,800.00 45,850.00 S170 “P-36-4” page “P-36-4” page 10366 92,960.00 Annex 14 60,000.00 32,960.00 659,20 1024 & 1026 537 10371 21,000.00 4,400.00 | “P-39-3” page 16,600.00 332.00 “P-39-3” page 47 & 48;

“P-36-4” page 560 “P-39-3” pages 198, 199, 204 to 206;

10410

Subtotal

Total

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

194;

"P-36-4" page 1029 "P-39-3" pages 44,160.00

Annex 14

9,000.00 201 to 203;

35,160.00 "P-36-4" page 1066 703.20 p 1,186,082.00 p 169,650.00 t-1,016,432.00 p 20,328.64 P14,950,073.95 P6,100,831.54 P8,849,242.41 P176,984.84 Consequently, only P1,230,401,742.63 of the income payments reported by the !CPA as having been traced were verified by the Court as forming part of the income declared in petitioner's AITR for CY 2020, with corresponding CWTs of P25,762,974.39, as follows:

Income payment

CWT

Income payment traced per !CPA p 1 ,239,250, 985.04 p 25,939,959.23 findings Less: Not traced to income per the 8,849,242.41 176,984.84 Court's further verification Income payments traced as P1,230,401, 742.63 P25, 762,974.39 verified In view of the foregoing, the Court finds that, out of the substantiated CWTs of P30,208,502.00, only the amount of P25,762,974.39 satisfies the third requisite for the refund of unutilized CWTs, i.e., that the income payments upon which the said CWTs were withheld were declared as part of petitioner's gross income in its AITR for CY 2020.

WHEREFORE, premises considered, petitioner's Motion for Reconsideration (Re: Decision dated 22, [sic] January 2026) is PARTIALLY GRANTED.

Accordingly, the dispositive portion of the Decision dated January 22, 2026, is hereby AMENDED to read as follows: "WHEREFORE, 1n light of the foregoing considerations, the present Petition for Review is

PARTIALLY

GRANTED.

Respondent is hereby ORDERED TO REFUND petitioner the amount of P25,762,974.39, representing the latter's unutilized creditable withholding taxes for calendar year 2020.

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

Associate Justice

!CONCUR:

~/~

BACORRO-VILLENA

ATTESTATION

I attest that the conclusions in the above Amended Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. \ ~ A. BACORRO-VILLENA iate Justice ~~

Chairperson

AMENDED DECISION

CTA Case No. 11129 Samsung SDS Global SCL Philippines Co., Ltd. Inc. v. Commissioner of Internal

Revenue

CERTIFICATION

Pursuant to Article VIII, Section 13 of the Constitution, and the

Special

First

Division

Acting

Chairperson's

Attestation, it is hereby certified that the conclusions in the above Amended Decision were reached in consultation before the case was assigned to the writer of the opinion of the Court's Division.

~.~ t--.

MA. BELEN M. RINGPIS-LIBAN

Presiding Justice