Philippine Bar review · Question

Practice question: Construction and Interpretation of Tax Laws and Tax Exemptions

Multiple Choice Easy Jurisprudence

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?
  1. Prejudicial retroactive application of that change
  2. Every prospective change in every law
  3. Every judicial review of tax interpretation
  4. Every future tax assessment regardless of law
  5. 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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