Practice question
BIR subsequently gathers facts materially different from those on which a ruling was based. The taxpayer says Section246(b) cannot apply unless BIR also proves a deliberate misstatement under subsection(a). What does G&W Architects2026 MAIN hold?
- Subsection(b) does not require the deliberateness demanded by subsection(a)
- Subsections(a) and(b) have identical deliberate-misstatement elements
- Subsection(b) was repealed by the main decision
- Good faith automatically removes every materially-different-facts exception
- The Court held that only a separate opinion can interpret subsection(b)
Legal references
- NIRC under RA8424, relevant unchanged provisions: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section246(a)–(b).
- CIR v. G&W Architects, GR246026, April21 2026, Dimaampao MAIN: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70567 MAIN comparison of first and second exceptions.
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