Practice question
What consequence does NIRC Section246 generally prevent when a BIR ruling is revoked, modified or reversed to taxpayer prejudice and no listed exception applies?
- Prejudicial retroactive application of that change
- Every prospective change in every law
- Every judicial review of tax interpretation
- Every future tax assessment regardless of law
- Only the correction of typographical spacing
Legal references
- NIRC under RA8424, relevant unchanged provisions: https://lawphil.net/statutes/repacts/ra1997/ra_8424_1997.html Section246.
- CIR v. G&W Architects, GR246026, April21 2026, Dimaampao MAIN: https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/70567 MAIN Section246(b) materially-different-facts exception, before the main dispositive portion.
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