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Commercial and Taxation Laws
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Ardent Global, Inc., a Philippine-based software development company that provides IT-enabled services to foreign clients, challenges a CTA Division decision sustaining a BIR corporate income tax deficiency arising from intercompany service transactions. The Division denies the petition, and Ardent files a petition for review with the CTA En Banc on the ground of grave abuse of discretion amounting to lack or excess of jurisdiction, contending misapplication of tax rules on intercompany income. The En Banc denies the petition. Which statement about CTA En Banc review is correct?