Practice question
In G&W Architects, BIR rulings had described the taxpayer as a project proponent and organizer. The main decision found the subsequently established transaction facts materially different and applied Section246(b). A student instead quotes an embedded separate opinion saying none of the exceptions existed. Which correctly reports the controlling MAIN outcome?
- The main decision applied the materially-different-facts exception and did not require deliberate misstatement for that subsection
- The contrary separate opinion supplied the main holding
- The main decision declared subsection(b) unconstitutional
- Every prior BIR ruling was made irrevocable forever
- The Court required proof of criminal conviction before subsection(b) could apply
Legal references
- CIR v. G&W Architects, GR246026, April21 2026, Dimaampao MAIN: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70567 MAIN discussion of Section246(b), BIR Ruling DA-455-2007 and RMC55-2010.
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